FROM: Adam Hall

Rainbow Bridge Media, LLC.

46-039 Lilipuna Road

Kaneohe, HI 96744

TO: Federal Aviation Administration

US Department of Transportation

Docket Management System

1200 New Jersey Ave. S.E

Washington, DC . 20590

October 23, 2015

Re: Exemption Request Pursuant to Section 333 of the FAA Reform Act and Part 11 of the Federal Aviation 

Regulations from: 14 CFR Part 21 subpart H, 14 CFR 45.23 (b),14 CFR 61.23 (a) , 14 CFR 61.113 (a) & (b), 14 

CFR 61.315(a), 14 CFR 91.7 (a), 14 CFR 91.9 (b) (2), 14 CFR 91.103, 14 CFR 91.109, 14 CFR 91.119 (c), 14 CFR 

91.121, 14 CFR 91.151 (a) & (b), 14 CFR 91.203 (a) & (b), 14 CFR 91.405 (a), 14 CFR 91.407 (a) (1), 14 CFR 

91.409 (a) (2) & 14 CFR 91.417 (a) & (b)

Dear Sir or Madam:

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the “Reform Act”) and 14 CFR 

Part 11, Adam Hall, Owner and Operator of an Rainbow Bridge Media, LLC, hereby applies for an exemption 

from the listed Federal Aviation Regulations (“FARs”) to allow commercial operation of its UAS including 

closed-set motion picture and television filming, 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. 

Rainbow Bridge Media’s commercial operation of the Unmanned Aircraft System (UAS), as described herein, 

which are equipped with camera(s) and sensors, would operate in the following manner:

 Aerial photography and/or video for public and/or private use including real estate, architecture, 

land surveying, mapping, engineering and other related professional activities.

 Aerial video and/or photography for public and/or private use including television, motion picture, 

public events, cinematography and news gathering including closed-set filming for the motion 

picture and television industry in accordance with the Motion Picture and Television Operations 

Manual (MPTOM) for flights covered under this Exemption Request, specifically those for sterile 

environments and closed set motion picture and television productions.

 Aerial inspection/photography of residential/commercial structures under contract with the owners 
or local government authority.

 Aerial inspection/photography of residential/commercial utility infrastructure including but not 

limited to electrical power lines, wind turbines and cell towers.

 Aerial video/photography or providing live video feed to assist with search and rescue operations in 

cases of an emergency or natural disaster only when the local authorities or government has 

requested it by contract or donation.

As described fully below, the requested exemption would permit the operation of a UAS under controlled 

conditions in the NAS that would be a) limited b) controlled c) predetermined and d) will provide safety 

enhancements to the already safe operations in the industry presently using conventional aircraft. Approval 

of this exemption would thereby enhance safety and fulfill the Secretary of Transportation’s (the FAA 

Administrator’s) responsibilities to “....establish requirements for the safe operation of such aircraft systems 

in the national airspace system.”

The name and address of the applicant is:

Adam Hall

DBA: Rainbow Bridge Media, LLC.

46-039 Lilipuna Road, Kaneohe, HI 96744

Email: adamhall.02@gmail.com

Regulations from which the exemption is requested:

14 CFR Part 21 subpart H

14 CFR 45.23 (b)

14 CFR 61.23 (a) 

14 CFR 61.113 (a) & (b)

14 CFR 61.315(a)

14 CFR 91.7 (a)

14 CFR 91.9 (b) (2)

14 CFR 91.103

14 CFR 91.109

14 CFR 91.119 (c)

14 CFR 91.121

14 CFR 91.151 (a) & (b)

14 CFR 91.203 (a) & (b)

14 CFR 91.405 (a)

14 CFR 91.407 (a) (1)

14 CFR 91.409 (a) (2)

14 CFR 91.417 (a) & (b)
Introduction & Background

Rainbow Bridge Media LLC is a professional photographer, videographer, data collection and production 

company operating primarily in Oregon and Hawaii. Adam Hall, operator, has over 7 years of professional 

experience in Communication Information Technology and is recognized as an expert in telecommunications 

network infrastructure. In addition, He has over 5 years recreational/hobby experience in all aspects of aerial 

video and photography. The objectives of Rainbow Bridge Media LLC’s aerial video and photography 

operations are to provide high quality imagery and data for a variety of commercial, agricultural, and 

residential uses. Rainbow Bridge Media provides its clients with solutions to increase efficiency, productivity 

and effectiveness. 

One example of Rainbow Bridge Media’s benefits to society can be found in aerial videography for real 

estate. Aerial photography for real estate has been around for a long time through manned fixed wing 

aircraft and helicopters. With such a large expense, small budget real estate companies and as well as simple 

homeowners cannot partake in the benefit of having aerial imagery because the cost is so prohibitive. Only 

large companies and high end Realtors or luxury homeowners can afford to absorb such expense. This has 

depriving non-luxury homeowners and lower budget Realtors from a valuable marketing tool.

Congress has already proclaimed that it is in the public’s interest to integrate commercially flown UAS's into 

the national airspace system, hence the passing of the Reform Act.

Granting Rainbow Bridge Media’s exemption request furthers the public interest through academic/visual 

awareness of the geographical benefits in and around Hawaii and Oregon. Our ultra-light weight UAS’ are 

battery powered and create no emissions that can harm the environment. The consequence of either ultralight weight UAS crashing are far less than a full size helicopter or fixed wing aircraft; which are heavy, 

contain combustible fuel and can cause catastrophic devastation to the public.

The public’s interest is furthered by minimizing ecological and crash threats by permitting Rainbow Bridge 

Media with the ability to capture aerial video/photo/data through the battery operated ultra-light weight 

UAS's. Furthermore, permitting Rainbow Bridge Media LLC, to immediately fly within national air space 

furthers economic growth. Granting our exemption request substantially furthers the economic impact for 

the local community as well as for companies looking to relocate or build in the area as well as individuals 

looking to relocate for career advancement.

AIRCRAFT AND EQUIVALENT LEVEL OF SAFETY

As the primary pilot, Adam Hall, has an in-depth understanding of the capabilities and safety concerns 

involved in using this technology as an asset to the community. Satisfaction of criteria provided in Section 

333 of the Reform Act of 2012 provide more than adequate justification for the grant of the requested 

exemptions allowing the commercial operation of Rainbow Bridge LLC’s UAS.

Rainbow Bridge Media only utilizes safe and reliable UASs. DJI is an industry leader in small UAS production. 

DJI UASs are loaded with ground breaking software enabling the user to set parameters which will not allow 

flight into controlled airspace. Parameters can also be set to limit flight to no higher than a predetermined 

and set altitude as well as limit flight to a predetermined and set distance. In addition, DJI software provides 

real-time altitude and location information to the PIC via the linked monitor (smart phone/tablet devices)
UAS: DJI Inspire 1 and DJI Spreading Wings S1000+.

The DJI Inspire 1 and DJI Spreading Wings S1000+ are 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 6 pounds 7.5 ounces, a length of 17.3 inches, width of 17.7 

inches, height of 11.8 inches, and a maximum speed of approximately 40-42 knots. The DJI Inspire 1 is 

equipped with four main rotors; driven by Lithium Polymer battery powered electric motors

The Spreading Wings S1000+ has a maximum gross weight of 13-22 pounds, a length of 19.3 inches, width of 

19.7 inches, height of 14.8 inches, and a maximum speed of approximately 30 knots. The Spreading Wings 

S1000+ is equipped with eight main rotors; driven by Lithium Polymer battery powered electric motors and 

the S1000+ is built to carry a heavier payload for and supremely stable platform that is designed for advanced 

photography and cinematography.

Further Details on EACH UA can be found in the appendix

Both Models feature autonomous control and manual control abilities. Both can be programmed to limit their 

altitudes, and to avoid airspace with lateral limitations They also feature the ability to automatically 

compensate for motor failures, and will automatically return to base for low battery situations and signal 

disruptions.

Both of these models have operational speeds and weights that are well in line with the FAA limitations (less 

than 25 pounds max with payload, around 40 knots max speed) and they have been previously approved on 

multiple occasions. Rainbow Bridge chose DGI as a manufacturer due to their industry leading expertise and 

experience. These models have many hours of operational history behind them, and are inherently safer due 

to their having 4-8 rotors for redundancy, rigid construction, and light weight.

Given the small size of the UAS and the controlled environment provided the proposed operations will adhere 

to the Reform Act’s safety requirements. The approval of this application presents no national security 

issues. Regarding the level of safety surrounding the proposed operations and the public benefit, reduction 

in environmental impacts, including but not limited to reduced emissions and noise, the grant o f the 

requested exemption is in the public interest. Accordingly the applicant requests that the FAA grant the 

requested exemption with minimum delay.

Further limitations and conditions to which Rainbow Bridge Media agrees to adhere to when conducting 

commercial operations under the FAA issued exemption as set forth in the Flight Operations Manual (FOM) 

include:

 The UAS will weigh less than 55 lbs including payload. 

 The UAS will have a maximum operating speed of no more than 35mph.

 Flights will be operated within line of sight of the Pilot in Command (PIC) and/or Visual Observer 

(VO).

 Maximum flight time for each operational flight will be 20 minutes. Flights will be terminated at 25% 

battery power reserve or 20 minutes of flight time whichever occurs first.
 Flights will be operated at an altitude of no more than 400 feet Above Ground Level (AGL) and not 

more than 200 feet above an elevated platform from which filming is planned.

 Minimum crew for each operation will consist of the UAS Pilot, the Visual Observer (VO) and may 

include but not limited to a Camera Operator.

 The UAS pilot will be a designated Pilot in Command (PIC) and will take and pass all necessary 

certifications currently being approved by the FAA administration for commercial use.

 A briefing will be performed regarding the planned UAS operations prior to each day’s flight

consisting of all the days’ production activities.

 All flights will occur under Visual Flight Rules Meteorological Conditions (VMC) only.

 The flights will occur no closer than a 5 mile radius of the geographic center/Airport Reference Point 

(ARP) of a tower controlled or uncontrolled airport. The DJI Inspire has built in software for all FAA 

regulated ‘No Fly Zones’ and was uploaded by DJI (2015) for all DJI drones to download and prevent 

any possible flights occurring within no-fly zones. DJI Spreading Wings S1000+ has installed software 

(code) that denies flights within the FAA no-fly zones.

 If operations will be within a 5 mile radius of the geographic center/Airport Reference Point (ARP) of 

a tower controlled or uncontrolled airport the respective airports will be contacted advising them of 

the estimated flight time, flight duration, elevation of flight and other pertinent information.

 The operator will file FAA Form 7711-1, or its equivalent, as modified in light of the requested 

exemption, with the appropriate local Flight Standards District Office (FSDO) no more than 72 hours 

but no less than 48 hours from planned operation.

 The operator will obtain verbal/written consent of all persons involved with the planned operation 

and ensure that only consenting persons will be allowed within 100 feet of the flight operation, and 

the radius may be reduced to 30 feet based upon an equivalent level of safety determination, as 

required under the FOM. With the advanced permission of the FSDO, operations at closer range may 

be approved.

 The PIC and VO will have been trained in operation of UAS and receive up-to-date information for 

the particular UAS to be operated.

 The PIC and VO will be able to communicate by voice, radio, and/or text at all times.

 Written and/or verbal permission and permits will be obtained from territorial, state, county or city 

jurisdictions, including law enforcement, fire or other appropriate governmental agencies.

 If the UAS loses communications with the remote controller or loses GPS signal, the UAS will have 

the capability to return to a pre-determined location within a designated location and land 

autonomously.

 The UA 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 or U.S. driver’s license.

 The UA must remain clear and give way to all manned aviation operations and activities at all times. 

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

 The operator must have a motion picture and television operations manual (MPTOM) as documented 

in this grant of exemption.

 Any incident, accident, or flight operation that transgresses the lateral or vertical boundaries of the 

operational area will be reported to the FAA’s UAS Integration Office (AFS-80) within 24 hours. 

Accidents will be reported to the National Transportation Safety Board (NTSB) per instructions 

contained on the NTSB Web site: www.ntsb.gov. 

 We are further requesting that this exemption permits operations for the purpose of closed-set 

motion picture and television filming and production, the following additional conditions and 

limitations apply:

 Rainbow Bridge Media will have a motion picture and television operations manual (MPTOM) as 

documented in this grant of exemption. 

 At least 3 days before aerial filming, Rainbow Bridge Media will submit a written Plan of Activities to 

the local Flight Standards District Office (FSDO) with jurisdiction over the area of proposed filming.

The 3-day notification may be waived with the concurrence of the FSDO. The plan of activities must 

include at least the following: 

a) Dates and times for all flights; 

b) Name and phone number of the operator for the sUAS aerial filming conducted under this grant of 

exemption; 

c) Name and phone number of the person responsible for the on-scene operation of the sUAS; 

d) Make, model, and serial or N-Number of the sUAS to be used; 

e) Name and certificate number of sUAS PICs involved in the aerial filming; 

f) A statement that the operator has obtained permission from property owners and/or local officials 

to conduct the filming production event; the list of those who gave permission will be made available 

to the inspector upon request; 

g) Signature of exemption holder or representative; and 

h) A description of the flight activity, including maps or diagrams of any area, city, town, county, and/or 

state over which filming will be conducted and the altitudes essential to ac complish the operation. 

31.
 Flight operations may be conducted closer than 500 feet from participating persons consenting to be 

involved and necessary for the filming production, as specified in the MPTOM.

 The UAS will have the capability to abort a flight in case of unpredicted obstacles, weather, or 

emergencies.

Rainbow Bridge Media pilots will be highly trained, will practice emergency procedures regularly, and will 

always have the safety of the public as the primary concern.

Rainbow Bridge Media’s Request are In the Best Public Interest; 

Granting Rainbow Bridge Media’s present Petition will further the public interest by allowing Rainbow Bridge 

Media to safely, efficiently, and economically perform aerial video and photography of construction sites, 

real estate, and landscape as well as data collection over certain areas of the United States.

Additionally, use of the DJI Inspire 1 and Spreading Wings S1000+ UASs will decrease congestion of the NAS, 

reduce pollution, and provide significant benefits to the economy. Notably, the benefits of Rainbow Bridge 

Media’s proposed operation of the DJI Inspire 1 and Spreading Wings S1000+ UASs will be realized without 

implicating any privacy issues.

1. The Public Will Benefit From Decreased Congestion Of The NAS.

The DJI Inspire 1 and Spreading Wings S1000+ UAs are battery powered and serve as a safe, efficient, 

and economical alternative to the manned aircraft traditionally utilized to obtain aerial 

imagery/data. By reducing the amount of manned aircraft needed to perform aerial acquisitions, an 

exemption allowing the use of the DJI Inspire 1 and Spreading Wings S1000+ 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 and Spreading 

Wings S1000+ 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 and Spreading Wings 

S1000+. Conducting aerial acquisitions with the DJI Inspire 1 and Spreading Wings S1000+, instead of 

manned aircraft, will greatly benefit the public by drastically reducing the levels of air and noise 

pollution generated during traditional aerial video and still photography flight operations. By using 

battery power and electric motors, the DJI Inspire 1 and Spreading Wings S1000+ UASs produce no 

air pollution, and is the most viable environmentally conscious alternative to the typical engine 

aircraft that are often utilized for aerial video and photography and Data Collection. The DJI Inspire 1 

and Spreading Wings S1000+ 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.

3. By using the DJI Inspire 1 and Spreading Wings S1000+ UASs 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 and 

Spreading Wings S1000+ UAs (weighing so little even at their fully loaded weight), have far 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.

4. Performing Aerial Video, Data Collection, and Photography Operations With The DJI Inspire 1 and 

Spreading Wings S1000+ UASs Will Benefit The Economy. In addition to being safe and efficient, the 

DJI Inspire 1 and Spreading Wings S1000+ UASs are also an economical alternative to using manned 

aircraft to conduct similar aerial operations. As such, operation of the the DJI Inspire 1 and Spreading 

Wings S1000+ UASs will allow United States based companies, like Rainbow Bridge Media, 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 and Spreading Wings 

S1000+ UASs 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 and Spreading Wings S1000+ UASs, 

Rainbow Bridge Media 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 and Spreading Wings S1000+ UASs, provide 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.

5. There Are No Privacy Issues. Similar to the manned aerial acquisition flight operations that have been 

conducted for years, Rainbow Bridge Medias proposed operation of the the DJI Inspire 1 and 

Spreading Wings S1000+ UASs will not implicate any privacy issues. Specifically, the DJI Inspire 1 and 

Spreading Wings S1000+ UASs will be operated only in compliance with operating documents (i.e., 

the Rainbow Bridge Media Operations Manual, Monthly Maintenance Logs, and the DJI Inspire 1 and 

Spreading Wings S1000+ Instruction Manuals) which requires property owner involvement as well as 

local law enforcement notification, and in accordance with the Federal Aviation Regulation.

Exemption Requests:

14 C.F.R. 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 the Rainbow Bridge Media, 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 U.S.C.§44701 (f)) 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 UAS. In all 

cases, an analysis of these criteria demonstrates that the UAS operated without an airworthiness certificate, 

in the restricted environment and under the conditions proposed will be at least as safe, or safer, than a 

conventional aircraft (fixed wing or rotorcraft) operating with an airworthiness certificate without the 

restrictions and conditions proposed. 
The UAS to be operated hereunder is less than 55 lbs. fully loaded, carries neither a pilot nor passenger, 

carries no explosive materials or flammable liquid fuels, and operates exclusively within a secured and 

designated area. Unlike other civil aircraft, operations under this exemption will be tightly controlled and 

monitored by both the operator and under the requirements and in compliance with local public safety 

requirements. The FAA will have advance notice of all operations. 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 UAS, due to its size, speed of 

operation, location of operation, lack of explosive materials or flammable liquid fuels, and inability to carry a 

substantial external load. 

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

The regulation requires: 

When marks include only the Roman capital letter "N" and the registration number is displayed on limited, 

restricted or light-sport category aircraft or experimental or provisionally certificated aircraft, the operator 

must also display on that aircraft near each entrance to the cabin, cockpit, or pilot station, in letters not less 

than 2 inches nor more than 6 inches high, the words "limited," "restricted," "light-sport," "experimental," or 

"provisional," as applicable. 

Even though the UAS will have no airworthiness certificate, an exemption will be needed as the UAS will have 

no entrance to the cabin, cockpit or pilot station on which the word “Experimental” can be placed. 

Given the size of the UAS, two-inch lettering will be impossible. The word “Experimental” will be placed on 

the fuselage in compliance with §45.29 (f). 

The equivalent level of safety will be provided by having the UAS marked on its fuselage as required by 

§45.29 (f) where the pilot, observer and others working with the UAS will see the identification of the UAS as 

“Experimental.” 

14 C.F.R. § 61.23(a)

The P.I.C. may have a valid U.S. driver’s license in lieu of a medical certificate. This is per FAA guidance. As 

each UAS can land itself the physical integrity of the PIC is not as important as that of a manned aircraft. Also, 

redundancy in the form of a visual observer will certainly add to safety. See previous Exemption No. 11343

14 C.F.R. § 61.113 (a) and (b): Private Pilot Privileges and Limitations: Pilot in Command.

Pursuant to 14 CFR 61.113 (a) & (b), no person who holds a private pilot certificate may act as a pilot in 

command of an aircraft that is carrying passengers or property for compensation or hire. An equivalent level 

of safety can be achieved by current Regulations because the applicant’s UAS do not carry any pilots or 

passengers nor property. The risks attendant to the operation of UAS is far less than the risk levels inherent 

in the commercial activities outlined in 14 CFR 61. The operation and limitations set forth in the FOM will 

equate to the safe operation of the UAS. See Exemption No. 11213
14 C.F.R. § 61.315(a)

Sport pilot limitations on commercial activity are not being applied to UAS. Rainbow Bridge also request the 

ability to utilize sport pilots assuming they will be held to the same training standards, as dictated by the 

F.O.M. See previous Exemption No 11407

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 for maintenance and use of safety check lists prior to each flight an equivalent 

level of safety will be provided. See Exemption Nos. 11062, 11063, 11064, 11065.

14 C.F.R. § 91.9 (b) (2): Civil Aircraft Flight Manual in the Aircraft.

Section 91.9 (b) (2) provides: No person may operate a U.S.-registered civil aircraft ... (2) For which an 

Airplane or Rotorcraft Flight Manual is not required by §21.5 of this chapter, unless there is available in the 

aircraft a current approved airplane or Rotorcraft Flight Manual, approved manual material, markings, and 

placards, or any combination thereof. The UAS, 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 UAS will have immediate 

access to it. 

14 C.F.R. § 91.103: Preflight Action.

This regulation requires each pilot in command to take certain actions before flight to insure the safety of 

flight. As FAA approved rotorcraft flight manuals will not be provided for the aircraft an exemption will be 

needed. The PIC will take all actions as stated in the manufacturer FOM in the pre-flight inspection section, 

including but not limited to reviewing weather, flight battery requirements, landing and takeoff distances and 

aircraft performance data before initiation of flight. 

14 C.F.R. §91.109: Flight Instruction. 

Section 91.103 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. UAS and remotely 

piloted aircraft, by their design 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 

approved exemptions for flight training without fully functional dual controls for a number of aircraft and for 

flight instruction in experimental aircraft. The equivalent level of safety provided by the fact that neither a 

pilot nor passengers will be carried in the aircraft and by the size and speed of the aircraft. 

14 C.F.R. §91.119 (c): Minimum Safe Altitudes. 

As in Exemption 11138 (DOUGLAS TRUDEAU), operations conducted closer than 500feet to the ground may 

require that the UA be operated closer than 500 feet to essential persons, or objects that would not be 
possible without additional relief. The petitioner requests modification, waiver or exemption and clarification 

concerning the terms “congested areas” and “densely populated”. The Petitioner requests waiver for this 

condition to allow reasonable and responsible operations near persons or property as needed. It should be 

noted that due to the small weight, controlled area of operation, lower speeds, computer backup, and lack of 

flammable fluids the UAS is inherently safer than equivalent manned aircraft. See Previous Exemption 11138

14 C.F.R. §91.121 Altimeter Settings. 

This regulation requires each person operating an aircraft to maintain cruising altitude by reference to an 

altimeter that is set “...to the elevation of the departure airport or an appropriate altimeter setti ng available 

before departure.” The equivalent level of safety established by Section 91.121 will be maintained because 

the altitude information of the DJI Inspire 1 and Spreading Wings S1000+ 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 Rainbow Bridge 

Medias operation of the Spreading Wings S1000+ and 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 See Previous Exemption Nos. 11062, 11063, 11064, 11065, 

11066, 11067, 11080, 11109, 11112, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 

11161).

14 C.F.R. § 91.151(a) & (b): Fuel Requirements for Flight in VFR Conditions 

Section 91.151 (a) prohibits an individual from beginning “a flight in an airplane 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 – (1) During the day, to fly after that for at least 30 minutes; or 

(2) At night, to fly after that for at least 45 minutes.” 

The battery powering the UAS provides approximately 25 minutes of powered flight. To meet the 30 minute 

reserve requirement in 14 CFR §91.151, UAS flights would be limited to approximately 10 minutes in length. 

Given the limitations on the DJI Inspire 1 and DJI Spreading Wings S1000+ proposed flight area and the 

location of its proposed operations within a predetermined area, a longer time frame for flight in daylight or 

twilight VFR conditions is reasonable. 

Rainbow Bridge Media believe that an exemption from 14 CFR §91.151(a) falls within the scope of prior 

exemptions. Operating the DJI Inspire 1 and DJI Spreading Wings S1000+, in a tightly controlled area, 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 small UAS. Additionally, limiting Rainbow Bridge Medias flights to 

10 minutes would greatly reduce and constrain the practicality of any aerial video or still photo flight 

operations that Rainbow Bridge Media proposes to conduct pursuant to this Petition.

Rainbow Bridge Media believes that an equivalent level of safety can be achieved by limiting flights to 20 

minutes or 25% of battery power— whichever happens first. This restriction would be more than adequate to 

return the UAS to its planned landing zone from anywhere in its limited operating area. 
A grant of part B exemption would ensure an equivalent level of safety established by (1) the technical 

specifications of the DJI Inspire 1 and DJI Spreading Wings S1000+ UASs; (2) the limitations on the proposed 

flight operations; and (3) the location of the proposed flight operations. Accordingly, Rainbow Bridge Media

will ensure that it will safely operate the battery powered DJI Inspire 1 and DJI Spreading Wings S1000+ UAs 

during daylight hours in VFR conditions, with enough battery power to fly for a total duration of 13.5 minutes

to the first point of intended landing and, assuming normal cruising speed, to fly after that for at least 4.5 

minutes. Furthermore, safety will be ensured as the DJI Inspire 1 and DJI Spreading Wings S1000+ provide 

audible and visual warnings to the PIC at the GCS when the UAs experiences low battery voltage, the first 

warning occurring at approximately 30% remaining battery power, and again at approximately 10% remaining 

battery power. At the critically low battery level, the DJI Inspire 1 and DJI Spreading Wings S1000+ UASs 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. 

Additionally, the FAA has previously granted relief from Section 91.151 specific to UAS, in circumstances 

similar, in all material respects, to those presented by Rainbow Bridge Media See 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).

14 C.F.R. §91.203 (a) and (b): Carrying Civil Aircraft Certification and Registration 

The regulation provides in pertinent 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. 

The DJI Inspire 1 and DJI Spreading Wings S1000+ fully loaded weighs no more than 55 lbs. and are operated 

without an onboard pilot. As such, there is no ability or place to carry certification and registration 

documents or to display them on the UAS’. 

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

the pilot flying the UAS will have immediate access to them; to the extent they are applicable.

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 section and Part 43 apply only to aircraft with an airworthiness certificate, these sections 

will not apply to the applicant. Maintenance will be accomplished by the Rainbow Bridge Media operator 

pursuant to the flight manual and operating handbook. An equivalent level of safety will be achieved because 

the DJI Inspire 1 and DJI Spreading Wings S1000+ UAS are both very limited in size, will carry a small payload 

and operate only in restricted areas for a limited period of time. If mechanical issues arise the DJI Inspire 1 

and DJI Spreading Wings S1000+ UAS can land immediately and will be operating from no higher than 400 

feet AGL. The Rainbow Bridge PIC will ensure that the UAS is in working order prior to initiating flight, 

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

An equivalent level of safety will be achieved because maintenance and inspections will be performed in 

accordance with the DJI Inspire 1 and DJI Spreading Wings S1000+ UAS Manufacturer's User Manual. As 

provided in the FOM, the PIC will ensure that the UAS is in working order prior to initiating flight and perform 

required maintenance needed.

CONCLUSION

As previously shown in Grants of Exemption Nos. 11062 to Astraeus Aerial (see Docket No. FAA−2014−0352), 

11109 to Clayco, Inc. (see Docket No. FAA−2014−0507), 11112 to VDOS Global, LLC (see Docket No. 

FAA−2014−0382), and 11213 to Aeryon Labs, Inc. (see Docket No. FAA−2014−0642), the FAA found that the 

enhanced safety achieved using an unmanned aircraft (UA) with the specifications described by the petitioner 

and carrying no passengers or crew, rather than a manned aircraft of significantly greater proportions, 

carrying crew in addition to flammable fuel, and gave good cause to find that the UAS operation enabled by 

this exemption is in the public interest and Rainbow Bridge Media is requesting the same exemptions.

As set forth herein, Rainbow Bridge Media 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 and DJI Spreading Wings S1000+ UASs commercially, without an airworthiness certificate, for the 

commercial purposes of conducting aerial video, data collection and photography over certain areas of the 

United States including closed-set filming for the motion picture and television industry. 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 Rainbow Bridge Media to 

safely, efficiently, and economically operate the DJI Inspire 1 and DJI Spreading Wings S1000+ commercially 

within the NAS.

WHEREFORE, in accordance with the Federal Aviation Regulations and the FAA Modernization and Reform Act 

of 2012, Section 333, Adam Hall and Rainbow Bridge Media respectfully requests that the Administrator grant 

this Petition for an exemption from the requirements set forth above and permit Rainbow Bridge Media to 

operate the DJI Inspire 1 and DJI Spreading Wings S1000+commercially for the purpose of conducting aerial 

video, data collection and photography over certain areas of the United States including closed set filming.

Respectfully Submitted,

Adam Hall

Owner

Rainbow Bridge Media LLC.
GLOSSARY OF ABBREVIATIONS

AGL: Above Ground Level

AOI: Area of Interest

ATC: Air Traffic Control

ATO: Air Traffic Organization

CFR: Code of Federal Regulations

COA: Certificate of Authorization

FAA: Federal Aviation Administration

FAR: Federal Aviation Regulation

GCS: Ground Control Station

GPS: Global Positioning System

LOL: Loss of Link

NAS: National Airspace System

NOTAM: Notice to Airman

PIC: Pilot In Command

SO: Safety Observer

SOP: Standard Operating Procedures

UA: Unmanned Aircraft

UAS: Unmanned Aircraft System

VFR: Visual Flight Rules

VLOS: Visual Line of Site

VMC: Visual Meteorological Conditions

VTOL: Vertical Takeoff and Landing
DJI Inspire

GENERAL FEATURES

 Ready to fly 

 3-axis camera stabilization 

 Precision flight and stable hovering 

 GPS/GLONASS positioning & auto return home 

 Onscreen real-time flight parameters 

 High Definition 4k Camera 

 Camera tilt control 

 Film straight down 

 Supports Adobe DNG RAW 

 Adobe lens profile support 

 Camera parameter settings 

 Album synchronization 

 FAA no-fly zones locked out via installed software

TRANSMITTER

 Operating Frequency:2.400 GHz – 2.483 GHz 

 Communication Distance(open area): CE: 2000m; FCC: 2000m 

 Receiver Sensitivity(1%PER):-101dBm +/- 2dBm 

 Transmitter Power: CE: 16dBm; FCC: 20dBm 

 Working Voltage: 1.2A @ 7.4V 

 Battery: 6000 mAh LiPo 2s

CAMERA

 Operating Environment Temperature: 0°C-40°C

 Max Resolution: 4096 x 2162p @ 24/25fps 

 FOV: 94°/ 85° 

 Sensor size: 1/2.3" 

 HD Recording: 4k p 24/25fps / 720p 60fps 

DJI VISION APP

 System Requirement of Mobile Device: iOS version 6.0 or above/ Android system version 4.0 or above 

 Mobile Device Support: Recommended: iPhone4s, iPhone5, iPhone5s, iPod Touch4, iPod Touch5; 

DJI Inspire 1 Details

Aircraft

Model – T600

Weight (Battery Included) – 6lbs 7.5291oz (2935g)

Hovering Accuracy (GPS Mode) – Vertical: 0.5m; Horizontal:2.5m

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

DJI Spreading Wings S1000+Details

Aircraft

Diagonal Wheelbase: 1045mm

Frame Arm Length: 386mm

Frame Arm Weight (Including Motor, ESC, Propeller):325g

Center Frame Diameter: 337.5mm

Center Frame Weight (with Landing Gear Mounting Base, Servos): 1330g

Landing Gear Size: 460mm (Length) ×511mm (Width) ×305mm (Height), (Top width: 155 mm)

Foldable Propeller: High strength performance engineered plastics, Size 15×5.2inch

Flight Parameters: Takeoff Weight 6.0Kg ~ 11.0Kg (depending on camera/gear attached)

Power Battery: LiPo (6S、10000mAh~20000mAh、15C (Min), Max Power Consumption4000W

Hover Power Consumption: 1500W (@9.5Kg Takeoff Weight)

Hover Time: 15min (@15000mAh & 9.5Kg Takeoff Weight)

Working Environment Temperature-10 °C ~ +40 °C