Bridgetek Communications, LLC

7017 S. Buffalo Dr. #1295 

Las Vegas, NV 89113 980-939-4120 tony@bridgtekcommunications.com

1

January 13, 2016

To: U. S. Department of Transportation Docket Operations

West Building Ground Floor, Room w12-140 1200 

New Jersey Ave, SE Washington, DC 20590 

RE: Bridgetek Communications, LLC 

REQUEST 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) 

 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) 
Bridgetek Communications, LLC

7017 S. Buffalo Dr. #1295 

Las Vegas, NV 89113 980-939-4120 tony@bridgtekcommunications.com

2

TABLE OF CONTENTS 

Page GLOSSARY OF ABBREVIATIONS...................................................................................3 

SUMMARY...................................................................................................................... .....4 

INTRODUCTION AND INTERESTS OF PETITIONER....................................................4 

BACKGROUND....................................................................................................................5

BASIS FOR PETITION.........................................................................................................5 

NAME AND ADDRESS OF PETITIONER.........................................................................6 

THE SPECIFIC SECTIONS OF 14 C.F.R. FROM WHICH THE BRIDGETEK COMMUNICATIONS, LLC 

SEEKS EXEMPTION............................................................................................................7

THE EXTENT OF RELIEF THE BRIDGETEK COMMUNICATIONS, LLC SEEKS AND THE REASON THE 

BRIDGETEK COMMUNICATIONS, LLC SEEKS THE 

RELIEF..............................................................9

THE REASONS WHY GRANTING THE BRIDGETEK COMMUNICATIONS, LLC’S REQUEST WOULD 

BE IN THE PUBLIC INTEREST ............................................................................................12

THE REASONS WHY GRANTING THE EXEMPTION TO THE BRIDGETEK COMMUNICATIONS, LLC 

WOULD NOT ADVERSELY AFFECT SAFETY..............................................................20

SUMMARY THAT CAN BE PUBLISHED IN THE FEDERAL REGISTER...................25

ANY ADDITIONAL INFORMATION, VIEWS, OR ARGUMENTS AVAILABLE TO SUPPORT THE 

BRIDGETEK COMMUNICATIONS, LLC’S REQUEST..................................................25 

CONCLUSION.....................................................................................................................26

APPENDICES......................................................................................... 26 
Bridgetek Communications, LLC

7017 S. Buffalo Dr. #1295 

Las Vegas, NV 89113 980-939-4120 tony@bridgtekcommunications.com

3

GLOSSARY OF ABBREVIATIONS 

AGL Above Ground Level 

AOI Area of Interest

ATC Air Traffic Control

ATO Air Traffic Organization 

AV Aerial Vehicle 

CFR Code of Federal Regulations 

COA Certificate of Authorization

FAA Federal Aviation Administration 

FAR Federal Aviation Regulation 

GCS Ground Control Station 

GPS Global Positioning System 

LOL Loss of Link

NAS National Airspace System 

NOTAM Notice to Airman 

PIC Pilot In Command

Section 333 FAA Modernization and Reform Act of 2012 (FMRA) 

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 
Bridgetek Communications, LLC

7017 S. Buffalo Dr. #1295 

Las Vegas, NV 89113 980-939-4120 tony@bridgtekcommunications.com

4

SUMMARY 

Bridgetek Communications, LLC hereafter referred to as The BRIDGETEK COMMUNICATIONS, 

LLC 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 The BRIDGETEK 

COMMUNICATIONS, LLC to operate an Unmanned Aircraft System (UAS) for the commercial 

purpose of conducting aerial video and photography of construction sites, residential and 

commercial real estate, civil landscapes and events over certain areas of the United States. 

INTRODUCTION AND INTERESTS OF THE PETITIONER 

The BRIDGETEK COMMUNICATIONS, LLC has for 8 years provided their clients (which include 

private sector businesses along with local state and federal agencies) with expertise and 

knowledge in video and multimedia marketing, advertising, public relations and training using 

advanced technologies and solutions. The BRIDGETEK COMMUNICATIONS, LLC has worked on 

several hundred productions over the past 8 years in all types of locations with a perfect client 

and employee safety record. In the past we have supplied our clients aerial IT solutions using 

balloons. The objective of The BRIDGETEK COMMUNICATIONS, LLC and our Unmanned Aircraft 

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

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

specifically targeting 

Aerial Topography Services

Periodic security services

Real estate marketing 

Agriculture and utility surveys

Event marketing services

Wedding photography and video services 

Business marketing campaigns

Company maintains staff with aircraft pilot license, and has over 200 hours of safety flying 

experience with UAV electric quadcopters recreationally for approximately 3 years without 

incident. 
Bridgetek Communications, LLC

7017 S. Buffalo Dr. #1295 

Las Vegas, NV 89113 980-939-4120 tony@bridgtekcommunications.com

5

BACKGROUND 

Unmanned Aircraft Systems: DJI Inspire 1, UAS The BRIDGETEK COMMUNICATIONS, LLC

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 2.8 lb. while having a 

diagonal dimension of 23.2”, a maximum speed of approximately 16.4’fps 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 The BRIDGETEK COMMUNICATIONS, LLC will 

be registered in accordance with 49 U.S.C. 44103, Registration of Aircraft, as well as 14 C.F.R 

Part 47, Aircraft Registration, and marked in accordance with 14 C.F.R. Part 45, Identification 

and Registration Marking. 

BASIS FOR PETITION 

Petitioner, The BRIDGETEK COMMUNICATIONS, LLC, pursuant to the provisions of the 

Federal Aviation Regulations (14 C.F.R. § 11.61) and the FAA Modernization and Reform Act of 

2012 (FMRA), Section 333, Special Rules for Certain Unmanned Aircraft Systems, hereby 

petitions the Administrator to commercially operate the DJI Inspire 1, 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, The BRIDGETEK COMMUNICATIONS, LLC 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, The BRIDGETEK COMMUNICATIONS, LLC requests relief from Sections 

91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b), as these sections set forth 

requirements for maintenance that only apply to aircraft with an airworthiness certificate. The 

BRIDGETEK COMMUNICATIONS, LLC submits that the requested relief is proper since an 

equivalent level of safety will be ensured. The BRIDGETEK COMMUNICATIONS, LLC 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, The BRIDGETEK COMMUNICATIONS, LLC 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 The BRIDGETEK 
Bridgetek Communications, LLC

7017 S. Buffalo Dr. #1295 

Las Vegas, NV 89113 980-939-4120 tony@bridgtekcommunications.com

6

COMMUNICATIONS, LLC 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 Phantom UAS in a manner consistent with this exemption, 

including evasive and emergency maneuvers and maintaining appropriate distances from 

people, vessels, vehicles and structures. 

The BRIDGETEK COMMUNICATIONS, LLC seeks relief from Section 91.7(a), entitled Civil 

aircraft airworthiness, because the DJI Inspire 1 UAS do not require an airworthiness certificate 

in accordance with 14 C.F.R. Part 21, Subpart H. As such, The BRIDGETEK COMMUNICATIONS, 

LLC 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. 

The BRIDGETEK COMMUNICATIONS, LLC also seeks an exemption from the 

requirements of Section 91.121, entitled A ltimeter 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 GCS for active 

monitoring of the flight path. This altitude information, combined with The BRIDGETEK 

COMMUNICATIONS, LLC’s 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, The BRIDGETEK COMMUNICATIONS, LLC seeks an exemption from the 

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

BRIDGETEK COMMUNICATIONS, LLC 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 23 

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, The BRIDGETEK COMMUNICATIONS, LLC provides the following 

information in support of its petition for exemption: 

A . Name and Address of Petitioner

The name and address of the Petitioner and point of contact is: 

Tony Yousefnejad 

President

Bridgetek Communications, LLC

7017 S. Buffalo Dr. #1295Las Vegas, NV 89113

980-939-4120 tony@bridgtekcommunications.com
Bridgetek Communications, LLC

7017 S. Buffalo Dr. #1295 

Las Vegas, NV 89113 980-939-4120 tony@bridgtekcommunications.com

7

B. The Specific Sections Of 14 C.F.R. From Which The BRIDGETEK COMMUNICATIONS, LLC

Seeks Exemption. 

1. The BRIDGETEK COMMUNICATIONS, LLC 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. The BRIDGETEK COMMUNICATIONS, LLC Seeks Exemption From The Requirements Of 

Section 91.7(a). 

Section 91.7, entitled Civil Air traffic Worthiness, subsection (a), states the following:

(a) No person may operate a civil aircraft unless it is in an airworthy condition.

3. T he BRIDGETEK COMMUNICATIONS, LLC 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. 
Bridgetek Communications, LLC

7017 S. Buffalo Dr. #1295 

Las Vegas, NV 89113 980-939-4120 tony@bridgtekcommunications.com

8

4. T he BRIDGETEK COMMUNICATIONS, LLC 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. T he BRIDGETEK COMMUNICATIONS, LLC Seeks Exemption From The Requirement Of 

Section 91.405(a). 

Section 91.405, entitled Maintenance required, subsection (a), states the following:

(a) 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. The BRIDGETEK COMMUNICATIONS, LLC 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. The BRIDGETEK COMMUNICATIONS, LLC Seeks Exemption From The Requirements Of 

Sections 91.409(a)(1) And 91.409(a)(2). Section 91.409, entitled inspection, 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. 
Bridgetek Communications, LLC

7017 S. Buffalo Dr. #1295 

Las Vegas, NV 89113 980-939-4120 tony@bridgtekcommunications.com

9

8. The BRIDGETEK COMMUNICATIONS, LLC 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.
Bridgetek Communications, LLC

7017 S. Buffalo Dr. #1295 

Las Vegas, NV 89113 980-939-4120 tony@bridgtekcommunications.com

10

 (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 The BRIDGETEK COMMUNICATIONS, LLC Seeks And The Reason The 

BRIDGETEK COMMUNICATIONS, LLC Seeks The Relief. 

1. Extent Of Relief The BRIDGETEK COMMUNICATIONS, LLC S eeks And The Reason The 

BRIDGETEK COMMUNICATIONS, LLC Seeks Relief From Section 61.113(a) And (b). 

Relief from Section 61.113(a) and (b) entitled Private pilot privileges and limitations: 

Pilot in command, is requested to the extent necessary to allow a PIC holding a private pilot or 

higher level certificate, as well as a current and valid airman medical certificate, and who has 

met certain flight-hour and currency requirements, to conduct the proposed UAS flight 

operations for compensation or hire. 

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

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

any business or employment if: 

(1) The flight is only incidental to that business or employment; and

(2) The aircraft does not carry passengers or property for compensation or hire. 

As set forth more fully below, The BRIDGETEK COMMUNICATIONS, LLC submits that an 

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

Inspire 1 UAS 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, The BRIDGETEK COMMUNICATIONS, LLC submits that all flights of the DJI 

Inspire 1 UAS, conducted by the PIC pursuant to the grant of this Petition: 

(1) will be incidental to The BRIDGETEK COMMUNICATIONS, LLC’s business; and

(2) will not carry passengers or property for compensation or hire. 

4. Extent Of Relief The BRIDGETEK COMMUNICATIONS, LLC Seeks And The Reason The 

BRIDGETEK COMMUNICATIONS, LLC Seeks Relief From Section 91.7(a). 

Relief from Section 91.7(a) entitled Civil aircraft airworthiness, is requested to the extent 

required to allow The BRIDGETEK COMMUNICATIONS, LLC to determine that the DJI Inspire 1

UAS are in airworthy condition prior to every flight by ensuring that the UAS is in compliance 

with the operating documents (i.e., the BRIDGETEK COMMUNICATIONS, LLC Aerial Operations 

Manual, Monthly Maintenance Log, and DJI Inspire 1 Instruction Manual). 
Bridgetek Communications, LLC

7017 S. Buffalo Dr. #1295 

Las Vegas, NV 89113 980-939-4120 tony@bridgtekcommunications.com

11

The BRIDGETEK COMMUNICATIONS, LLC seeks the requested relief because the DJI Inspire 1

UAS do not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. 

Therefore, The BRIDGETEK COMMUNICATIONS, LLC will ensure that the DJI Inspire 1 UAS are in 

airworthy condition based upon its compliance with the operating documents (i.e., Monthly 

Maintenance Log, and DJI Inspire 1) prior to every flight, and further, determine that the 

aircraft are in condition for safe flight, as stated in the conditions and limitations below. 

5. Extent Of Relief The BRIDGETEK COMMUNICATIONS, LLC Seeks And The Reason The 

BRIDGETEK COMMUNICATIONS, LLC Seeks Relief From Section 91.121. 

Relief from Section 91.121, entitled Altimeter settings, may be required to allow flight 

operations of the DJI Inspire 1 UAS, which utilize a barometric pressure sensor, GPS equipment, 

and a radio communications telemetry data link to downlink altitude information from the UA 

to the PIC at the ground control station (GCS). 

Since the FAA requires that any altitude information concerning UAS operations be reported 

to air traffic control (ATC) in feet above ground level (AGL), The BRIDGETEK COMMUNICATIONS, 

LLC seeks the requested relief because the DJI Inspire 1 UA’s altimeter may be set on the 

ground to zero feet AGL, rather than the local barometric pressure or field altitude, before each 

flight. 

Considering the limited altitude of the proposed operations, relief from 14 CFR 91.121 is 

sought to the extent necessary to comply with the applicable conditions and limitations stated 

below. As more fully set forth herein, an equivalent level of safety will be maintained since the 

DJI Inspire 1 UAS are equipped with a barometric pressure sensor and GPS equipment, which 

automatically ensures that a ground level pressure setting will be established prior to each 

flight, and provides the PIC with altitude information of the UA on the heads-up display of the 

GCS. 

6. Extent Of Relief The BRIDGETEK COMMUNICATIONS, LLC Seeks And The Reason The 

BRIDGETEK COMMUNICATIONS, LLC 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 23 minutes. 

The BRIDGETEK COMMUNICATIONS, LLC seeks the requested relief because without an 

exemption from Section 91.151(b), the flight time duration of the battery powered DJI Inspire 1

UAS will severely constrain the practicality of any aerial video or still photo flight operations 

that The BRIDGETEK COMMUNICATIONS, LLC 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 The BRIDGETEK COMMUNICATIONS, LLC’s proposed 

operating limitations, ensure that The BRIDGETEK COMMUNICATIONS, LLC will safely operate 
Bridgetek Communications, LLC

7017 S. Buffalo Dr. #1295 

Las Vegas, NV 89113 980-939-4120 tony@bridgtekcommunications.com

12

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 

23 minutes. 

5. Extent Of Relief The BRIDGETEK COMMUNICATIONS, LLC Seeks And The Reason The 

BRIDGETEK COMMUNICATIONS, LLC Seeks Relief From Sections 91.405(a), 91.407(a)(1), 

91.409(a)(1) & (a)(2), And 91.417(a) & (b). 

Since Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) only 

apply to aircraft with an airworthiness certificate, The BRIDGETEK COMMUNICATIONS, LLC

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, The BRIDGETEK COMMUNICATIONS, LLC will use trained technicians to 

perform maintenance, alterations, or preventive maintenance on the UAS using the methods, 

techniques, and practices prescribed in the UAS operating documents (i.e., the The BRIDGETEK 

COMMUNICATIONS, LLC Aerial Operations Manual, Monthly Maintenance Log, and DJI Inspire 1

Instruction Manual). 

Furthermore, The BRIDGETEK COMMUNICATIONS, LLC will document and maintain all 

maintenance records for the DJI Inspire 1 UAS. 

D. The Reasons Why Granting The BRIDGETEK COMMUNICATIONS, LLC Request Would Be In 

The Public Interest; That Is, How It Would Benefit The Public As A Whole. 

Granting the present Petition will further the public interest by allowing The BRIDGETEK 

COMMUNICATIONS, LLC to safely, efficiently, and economically perform aerial video and 

photography of construction sites, 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 The 

BRIDGETEK COMMUNICATIONS, LLC’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.
Bridgetek Communications, LLC

7017 S. Buffalo Dr. #1295 

Las Vegas, NV 89113 980-939-4120 tony@bridgtekcommunications.com

13

Furthermore, by reducing the number of manned aircraft operating in the NAS, 

congestion around airports caused by arriving and departing aircraft will be reduced. The DJI 

Inspire 1 UAS do not require an airport to takeoff or land. 

Likewise, a reduction of manned aircraft conducting aerial video and photography 

missions would result in fewer aircraft that must be handled by air traffic control during the 

ground, takeoff, departure, arrival, and landing phases of flight operations. 

2. The Public Will Benefit From The Safety And Efficiency Of The DJI Inspire 1 UAS. 

Conducting aerial acquisitions with the DJI Inspire 1 UAS, instead of manned aircraft, will 

greatly benefit the public by drastically reducing the levels of air and noise pollution generated 

during traditional aerial video and still photography flight operations. By using battery power 

and electric motors, the DJI Inspire 1 UAS produce no air pollution, and is the most viable 

environmentally conscious alternative to the cabin class, six cylinder internal combustion 

engine aircraft that are typically utilized for aerial video and photography, while burning 

approximately 20-30 gallons per hour of leaded aviation fuel. 

The DJI Inspire 1 UAS, while reducing the carbon footprint of aerial acquisitions, also 

eliminates noise pollution, as the 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 2.8 pounds at their maximum gross weight with diagonal 

dimension of 23.2 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 The BRIDGETEK 

COMMUNICATIONS, LLC, to remain competitive and contribute to growth of the U.S. economy. 

Specifically, with the rising cost of aviation fuel and the Environmental Protection Agency 

(“EPA”) regulatory actions phasing out leaded aviation fuels, U.S. owned and operated 

companies must adopt new and alternative technology in order to remain competitive.
Bridgetek Communications, LLC

7017 S. Buffalo Dr. #1295 

Las Vegas, NV 89113 980-939-4120 tony@bridgtekcommunications.com

14

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 The BRIDGETEK COMMUNICATIONS, LLC, 

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

employees and contractors, which will ultimately contribute to growth of the U.S. 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, The BRIDGETEK COMMUNICATIONS, LLC’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., the BRIDGETEK COMMUNICATIONS, LLC Aerial 

Operations Manual, 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 The BRIDGETEK COMMUNICATIONS, LLC 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, The BRIDGETEK COMMUNICATIONS, LLC’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 
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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, The BRIDGETEK COMMUNICATIONS, LLC

submits that the DJI Inspire 1 UAS can operate safely in the NAS pursuant to FMRA Section 333, 

as demonstrated by:

 (a) the characteristics of the DJI Inspire 1 UAS; 

 (b) the pilot certification requirement; and

 (c) the specific operating limitations.

a. The Specifications Of The DJI Inspire 1 UAS Demonstrate Its Safe Characteristics. 

The DJI Inspire 1 UAS does not create a hazard to users of the NAS or the public, or 

otherwise pose a threat to national security considering its size, weight, speed, and operational 

capability.

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, attached hereto as Appendix A.

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 at pages 17 of 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. 
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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 13 through 16 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 13 through 16 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. 

The BRIDGETEK COMMUNICATIONS, LLC 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. 

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

Limitations. 

In seeking this exemption, The BRIDGETEK COMMUNICATIONS, LLC 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 
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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.
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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 PIC must possess at least a private pilot certificate and at least a current thirdclass medical certificate. 

18. The operator may not permit any PIC to operate unless the PIC meets the operator’s 

qualification criteria and demonstrates the ability to safely operate the UAS in a manner 

consistent with how the UAS will be operated under the exemption, including evasive and 

emergency maneuvers and maintaining appropriate distances from persons, vessels, 

vehicles and structures. PIC qualification flight hours must be logged in a manner 

consistent with 14 C.F.R. § 61.51(b). Flights for the purposes of training the operator’s 

PICs are permitted under the terms of the exemption. However, training operations may 

only be conducted during dedicated training sessions. During training, proficiency, and 

experience-building flights, all persons not essential for flight operations are considered 

nonparticipants, and the PIC must operate the UA with appropriate distance from 

nonparticipants in accordance with 14 C.F.R. § 91.119. 

19. UAS operations may not be conducted during night, as defined in 14 C.F.R. § 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.

20. The UA may not operate within 5 nautical miles of an airport reference point as 

denoted on a current FAA-published aeronautical chart unless a letter of agreement with 

that airport’s management is obtained, and the operation is conducted in accordance 

with a NOTAM as required by the operator’s COA. The letter of agreement with the 

airport management must be made available to the Administrator upon request.

21. The UA may not be operated less than 500 feet below or less than 2,000 feet 

horizontally from a cloud or when visibility is less than 3 statute miles from the PIC.

22. If the UA loses communications or loses its GPS signal, it must return to a predetermined location within the planned operating area and land or be recovered in 

accordance with the operating documents.
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23. The PIC must abort the flight in the event of unpredicted obstacles or emergencies in 

accordance with the operating documents.

24. The PIC is prohibited from beginning a flight unless (considering wind and forecast 

weather conditions) there is enough power to fly at normal cruising speed to the 

intended landing point and land the UA with 25% battery power remaining.

25. The operator must obtain an Air Traffic Organization (ATO) issued Certificate of 

Waiver or Authorization (COA) prior to conducting any operations under the grant of 

exemption. This COA will also require the operator to request a Notice to Airman 

(NOTAM) not more than 72 hours in advance, but not less than 48 hours prior to the 

operation. All operations shall be conducted in accordance with airspace requirements in 

the ATO issued COA including class of airspace, altitude level and potential transponder 

requirements.

26. All aircraft operated in accordance with the exemption must be identified by serial 

number, registered in accordance with 14 C.F.R. part 47, and have identification (NNumber) markings in accordance with 14 C.F.R. part 45, Subpart C. Markings must be as 

large as practicable. 

27. Before conducting operations, the radio frequency spectrum used for operation and 

control of the UA must comply with the Federal Communications Commission (FCC) or 

other appropriate government oversight agency requirements.

28. The documents required fewer than 14 C.F.R. 91.9 and 91.203 must be available to 

the PIC at the Ground Control Station of the UAS any time the UAS is operating. These 

documents must be made available to the Administrator or any law enforcement official 

upon request. 

29. The UA must remain clear and yield the right of way to all manned aviation operations 

and activities at all times.

30. The UAS may not be operated by the PIC from any moving device or vehicle.
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31. Flight operations must be conducted at least 500 feet from all nonparticipating 

persons (persons other than the PIC, SO, operator trainees or essential persons), vessels, 

vehicles, and structures unless: 

 a. Barriers or structures are present that sufficiently protect nonparticipating persons 

from the UA and/or debris in the event of an accident. The operator must ensure that 

nonparticipating persons remain under such protection. If a situation arises where 

nonparticipating persons leave such protection and are within 500 feet of the UA, flight 

operations must cease 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).

 32. All operations shall be conducted over private or controlled-access property with 

permission from the land owner/controller or authorized representative. Permission from 

land owner/controller or authorized representative will be obtained for each flight to be 

conducted. 

 33. Any incident, accident, or flight operation that transgresses the lateral or vertical 

boundaries of the operational area as defined by the applicable COA must be reported to 

the FAA's UAS Integration Office (AFS-80) within 24 hours. Accidents must be reported to 

the National Transportation Safety Board (NTSB) per instructions contained on the NTSB 

Web site: www.ntsb.gov.

2. Reasons Why An Exemption From The Requirements Of Section 61.113(a) And (b) Would 

Not Adversely Affect Safety. 

The BRIDGETEK COMMUNICATIONS, LLC submits that the equivalent level of safety 

established by Section 61.113(a) and (b) will be maintained because no PIC will be allowed to 

operate the DJI Inspire 1 UAS unless that PIC has demonstrated, by meeting minimum 

flight-hour and currency requirements, that the PIC is able to safely operate the DJI Inspire 1

UAS in a manner consistent with the exemption, including evasive and emergency maneuvers 

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

Considering The BRIDGETEK COMMUNICATIONS, LLC’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, The 

BRIDGETEK COMMUNICATIONS, LLC submits that the additional manned airmanship experience 
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of a commercially certificated pilot would not correlate to the airmanship skills necessary for 

The BRIDGETEK COMMUNICATIONS, LLC’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).

The BRIDGETEK COMMUNICATIONS, LLC will not allow any PIC to operate the DJI Inspire 

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

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

LLC’s 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, 
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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, The BRIDGETEK COMMUNICATIONS, LLC will ensure safe operations by not 

allowing any PIC to operate the DJI Inspire 1 UAS unless that PIC has demonstrated, by meeting 

minimum flight-hour and currency requirements, that the PIC is able to safely operate the DJI 

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

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

structures. 

3. Reasons Why An Exemption From The Requirements Of Section 91.7(a) Would Not 

Adversely Affect Safety. 

The equivalent level of safety established by Section 91.7(a) will be maintained because 

prior to every flight, The BRIDGETEK COMMUNICATIONS, LLC will ensure that the DJI Inspire 1

UAS is in an airworthy condition based upon the UAS’s compliance with its operating 

documents and as stated in the conditions and limitations herein. 

Additionally, the FAA has previously granted relief from Section 91.7(a) specific to UAS, 

in circumstances similar, in all material respects, to those presented herein (e.g. Exemption 

Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112, 11136, 11138, 

11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161). 

4. Reasons Why An Exemption From The Requirements Of Section 91.121 Would Not 

Adversely Affect Safety. 

The equivalent level of safety established by Section 91.121 will be maintained because 

the altitude information of the DJI Inspire 1 UAS will be provided to the PIC via GPS equipment 

and a radio communications telemetry data link, which downlinks from the UA to the GCS for 

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

BRIDGETEK COMMUNICATIONS, LLC’s operation of the DJI Inspire 1 UAS within visual line of 

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

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

aircraft. Prior to each flight, a zero altitude initiation point 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. 
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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, The BRIDGETEK COMMUNICATIONS, LLC 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 23 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, The BRIDGETEK COMMUNICATIONS, LLC submits that the 

equivalent level of safety with regard to the regulatory maintenance and alteration 

requirements established by Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 

91.417(a) & (b) will be met because The BRIDGETEK COMMUNICATIONS, LLC will use trained 

technicians to perform maintenance, alterations, or preventive maintenance on the UAS using 

the methods, techniques, and practices prescribed in the operating documents (i.e., the 

BRIDGETEK COMMUNICATIONS, LLC Aerial Operations Manual, Monthly Maintenance Log, and 

DJI Inspire 1 Instruction Manual). 

Furthermore, The BRIDGETEK COMMUNICATIONS, LLC will document and maintain all 

maintenance records for the DJI Inspire 1 UAS. Since the DJI Inspire 1 UAS will be inspected as 

prescribed by the operating documents, The BRIDGETEK COMMUNICATIONS, LLC will maintain 

the equivalent level of safety established by Sections 91.405(a), 91.409(a)(1), and 91.409(a)(2). 
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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 The BRIDGETEK 

COMMUNICATIONS, LLC will use trained technicians to perform maintenance, alterations or 

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

by the operating documents. Furthermore, the exemption sought would maintain an equivalent 

level of safety established by Sections 91.407, 91.417(a) and 91.417(b), because all 

maintenance of the DJI Inspire 1 UAS will be performed by trained technicians.

Maintenance will be documented and maintained utilizing the monthly maintenance 

log. Significantly, previous exemptions granted by the FAA concerning Sections 91.405(a), 

91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) establish that safety is not adversely 

affected when the technical characteristics and operating limitations of the UAS are considered.

In consideration of The BRIDGETEK COMMUNICATIONS, LLC’s proposed operating 

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

BRIDGETEK COMMUNICATIONS, LLC submits that safety will not be adversely affected by 

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

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

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

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

11157, 11158, 11159, 11160, 11161). 

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, The BRIDGETEK COMMUNICATIONS, 

LLC requests that the FAA prescribe special conditions for the intended operation of the DJI 

Inspire 1 UAS, which contain such safety standards that the Administrator finds necessary to 

establish a level of safety equivalent to that established by 14 C.F.R. Part 21, Subpart H, and 14 

C.F.R §§ 61.113(a) & (b), 91.7 (a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & 

(a)(2), and 91.417(a) & (b). Such special conditions will permit safe operation of the UAS for the 

limited purpose of conducting aerial video and photography over certain areas of the United 

States for compensation or hire. 

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

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

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

accordance with any requirements that must be established for the safe operation of the UAS 

in the NAS. 

Likewise, the Administrator may prescribe special conditions pursuant to 14 C.F.R. § 

21.16, for operation of the DJI Inspire 1 UAS, since the airworthiness regulations of 14 C.F.R. 
Bridgetek Communications, LLC

7017 S. Buffalo Dr. #1295 

Las Vegas, NV 89113 980-939-4120 tony@bridgtekcommunications.com

25

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 The BRIDGETEK COMMUNICATIONS, LLC Seeks Exemption: 

The BRIDGETEK COMMUNICATIONS, LLC 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 The BRIDGETEK 

COMMUNICATIONS, LLC Seeks: 

This exemption will permit The BRIDGETEK COMMUNICATIONS, LLC to commercially 

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

photography over certain areas of the United States. 

Any Additional Information, Views, Or Arguments Available To Support The 

BRIDGETEK COMMUNICATIONS, LLC’s 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, The BRIDGETEK COMMUNICATIONS, LLC’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, The BRIDGETEK COMMUNICATIONS, LLC will operate the DJI Inspire 1
Bridgetek Communications, LLC

7017 S. Buffalo Dr. #1295 

Las Vegas, NV 89113 980-939-4120 tony@bridgtekcommunications.com

26

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, The BRIDGETEK COMMUNICATIONS, LLC seeks an exemption 

pursuant to 14 C.F.R. § 11.61 and Section 333 of the FAA Modernization and Reform Act of 

2012 (FMRA), which will permit safe operation of the DJI Inspire 1 UAS commercially, without 

an airworthiness certificate, for the limited purpose of conducting aerial video and photography 

over certain areas of the United States. 

By granting this Petition, the FAA Administrator will be fulfilling the Congressional 

mandate of the FAA Modernization and Reform Act of 2012, while also advancing the interests 

of the public, by allowing The BRIDGETEK COMMUNICATIONS, LLC 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, The BRIDGETEK COMMUNICATIONS, LLC

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: December 23, 2015

Respectfully submitted, 

Tony Yousefnejad

Bridgetek Communications, LLC

7017 S. Buffalo Dr. #1295

Las Vegas, NV 89113

980-939-4120

tony@bridgtekcommunications.com

Appendices: 

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

https://dl.djicdn.com/downloads/inspire_1/en/Inspire_1_User_Manual_en_v2.0_1218.pdf