UNITED STATES OF AMERICA 

DEPARTMENT OF TRANSPORTATION 

FEDERAL AVIATION ADMINISTRATION 

WASHINGTON, DC

Regulatory Docket No. 

IN THE MATTER OF THE PETITION FOR EXEMPTION OF: 

GLENNAIRE LLC

FOR AN EXEMPTION SEEKING RELIEF FROM THE REQUIREMENTS OF

TITLE 14 OF THE CODE OF FEDERAL REGULATIONS SECTIONS 

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

91.409(a)(1) & (a)(2), AND 91.417(a) & (b) CONCERNING COMMERCIAL

OPERATION OF DJI INSPIRE 1 UNMANNED AIRCRAFT SYSTEMS

PURSUANT TO SECTION 333 OF

THE FAA MODERNIZATION AND REFORM ACT OF 2012

(PUBLIC LAW 112-95)

Submitted on September 13, 2015

Albert Glenn

Glennaire, LLC

5061 LeChateau Cove

Memphis,Tn.38125

Tel (901) 737-6597

Glennaireuav@gmail.com

Aglenn54@gmail.com
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TABLE OF CONTENTS

Page

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

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

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

BACKGROUND....................................................................................................................4

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

NAME AND ADDRESS OF PETITIONER.............................................................7

THE SPECIFIC SECTIONS OF 14 C.F.R. FROM WHICH GLENNAIRE LLC

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

THE EXTENT OF RELIEF GLENNAIRE LLC SEEKS AND THE REASON

GLENNAIRE LLC SEEKS THE RELIEF............................................................11

THE REASONS WHY GRANTING GLENNAIRE LLC’S REQUEST WOULD 

BE IN THE PUBLIC INTEREST .........................................................................14

THE REASONS WHY GRANTING THE EXEMPTION WOULD NOT 

ADVERSELY AFFECT SAFETY..........................................................................18

SUMMARY THAT CAN BE PUBLISHED IN THE FEDERAL REGISTER......32

ANY ADDITIONAL INFORMATION, VIEWS, OR ARGUMENTS 

AVAILABLE TO SUPPORT GLENNAIRE LLC’S REQUEST..........................32

CONCLUSION....................................................................................................................34

APPENDICES.........................................................................................35
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) Section 333

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
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SUMMARY

Albert Glenn 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 pursuant to Section 333 of 

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

Glennaire LLC to operate an Unmanned Aircraft System (UAS) for the commercial purpose

of conducting aerial video and photography.

INTRODUCTION AND INTERESTS OF THE PETITIONER

Glennaire is a full-service UAV system management and consulting firm, focusing on the 

needs of enterprise, entertainment and municipal clients across the Southeast. We partner 

with our clients to help them understand how UAV technology can transform their existing 

business practices to make them more efficient and competitive, and provide services to 

execute UAV strategies across multiple industries.

Glennaire Services:

UAV System Management Consulting

▪ Learn how UAVs impact your industry and how can you get ahead of the competition

▪ Understand the best ways to integrate UAV technology into your existing business 

operations

▪ Be advised on the proper equipment, personnel, and training needed to implement a UAV 

strategy

Aerial Photography and Videography

▪ Aircraft mapping and inspection

▪ Agricultural surveying

▪ Property Inspections

▪ Property security

▪ Sporting events

UAV Pilot Matching Platform

▪ Post your job on our platform to match with one of our certified UAV pilot
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BACKGROUND

Unmanned Aircraft Systems: DJI Inspire 1 UAS

Glennaire LLC seeks an exemption to operate DJI systemsfor compensation or 

hire within the NAS. The DJI Inspire 1 is a 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 pounds 11 ounces, while having a length of 16 inches width of 16 inches, height of 8 

inches, and a maximum speed of approximately 29 knots. The DJI Inspire 1 UA is

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

motors.

The DJI Inspire 1 UA, that will be operated by Glennaire 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, Glennaire 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, Glennaire LLC operation of DJ
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Phantom 2 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, Glennaire 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.

Glennaire LLC submits that the requested relief is proper since an equivalent level

of safety will be ensured. Glennaire LLC will use experienced personnel or technicians to

perform maintenance, alterations, or preventive maintenance on the UASs using the

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

Maintenance Log, and DJI Inspire 1 Instruction Manual). Furthermore, Glennaire 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 Glennaire 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 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.

Glennaire 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, Glennaire LLC submits that it
7

will ensure that the DJI Inspire 1 UAS are in an airworthy condition, prior to every flight,

by determining that the UASs 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. Glennaire LLC also seeks an exemption from the

requirements of Section 91.121, entitled Altimeter Settings, as the DJI Inspire 1 UA will

not have a typical barometric altimeter onboard. However, altitude information of the DJI 

Phantom 2 Inspire 1 UA 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 Glennaire 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.

Additionally, Glennaire LLC seeks an exemption from the requirements of Section

91.151(b), entitled Fuel requirements for flight in VFR conditions. Glennaire LLC

submits that safety will not be affected by operation of the DJI Inspire 1 UA 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 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.

In accordance with 14 C.F.R. § 11.81, Glennaire LLC provides the following 

information in support of its petition for exemption:

A. Name And Address Of The Petitioner.

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

5061 LeChateau Cove

Memphis TN 38125

Point of Contact: Albert Glenn

B. The Specific Sections Of 14 C.F.R. From Which Glennaire LLC Seeks Exemption.

1. Glennaire 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. Glennaire LLC Seeks Exemption From The Requirements Of Section

91.7(a).

Section 91.7, entitled Civil Aircraft Airworthiness, subsection (a), states

the following:

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

3. Glennaire LLC 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--
9

(1) Below 18,000 feet MSL, to--

(i) The current reported altimeter setting of a station along the route and 

within 100 nautical miles of the aircraft;

(ii) If there is no station within the area prescribed in paragraph (a)(1)(i) of 

this section, the current reported altimeter setting of an appropriate 

available station; or

(iii) In the case of an aircraft not equipped with a radio, the elevation of the 

departure airport or an appropriate altimeter setting available before 

departure.

4. Glennaire LLC 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. Glennaire LLC Exemption From The Requirement Of Section

91.405(a).

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

Each owner or operator of an aircraft—

(a) Shall have that aircraft inspected as prescribed in subpart E of this part and shall 

between required inspections, except as provided in paragraph (c) of this 

section, have discrepancies repaired as prescribed in part 43 of this chapter[.]

6. Glennaire LLC 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[.]
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7. Glennaire LLC Seeks Exemption From The Requirements Of Sections

91.409(a)(1) And 91.409(a)(2).

Section 91.409, entitled Inspections, subsection (a), states the following:

(a) Except as provided in paragraph (c) of this section, no person may operate an 

aircraft unless, within the preceding 12 calendar months, it has had --

(1) An annual inspection in accordance with part 43 of this chapter and has 

been approved for return to service by a person authorized by § 43.7 of this 

chapter; or

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

with part 21 of this chapter.

8. Glennaire LLC 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
11

which are required to be overhauled on a specified time basis.

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

the last inspection required by the inspection program under which

the aircraft and its appliances are maintained.

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

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

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

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

action is required.

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

major alteration to the airframe and currently installed engines,

rotors, propellers, and appliances.

(b) The owner or operator shall retain the following records for the

periods prescribed:

(1) The records specified in paragraph (a)(1) of this section shall be retained 

until the work is repeated or superseded by other work or for 1 year after

the work is performed.

(2) The records specified in paragraph (a)(2) of this section shall be

retained and transferred with the aircraft at the time the aircraft is sold.

(3) A list of defects furnished to a registered owner or operator under § 43.11 

of this chapter shall be retained until the defects are repaired and the

aircraft is approved for return to service.

C. The Extent Of Relief Glennaire LLC Seeks And The Reason Glennaire LLC 

Seeks The Relief.

1. Extent Of Relief Glennaire LLC Seeks And The Reason Glennaire 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
12

(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, Glennaire LLC submits that an equivalent level of 

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

UAS UA unless that PIC has met certain flight-hour and currency requirements, 

demonstrating that the PIC is able to safely operate either the DJI Phantom 2 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, Glennaire 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 

Glennaire LLC business; and (2) will not carry passengers or property for compensation

or hire.

2. Extent Of Relief Glennaire LLC Seeks And The Reason Glennaire 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 Glennaire 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 Glennaire LLC Aerial Operations Manual, Monthly

Maintenance Log, and DJI Inspire 1 Instruction Manual).

Glennaire LLC seeks the requested relief because the DJI Inspire 1 UAS does not

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

Therefore, Glennaire LLC will ensure that the DJI Inspire 1 UAS are in airworthy
13

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

Maintenance Log, and DJI Inspire 1 Instruction Manual) prior to every flight, and further,

determine that the aircraft are in condition for safe flight, as stated in the conditions and

limitations below.

3. Extent Of Relief Glennaire LLC Seeks And The Reason Glennaire 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), Glennaire LLC seeks the 

requested relief because the DJI Inspire 1UA’s altimeter may be set on the ground to zero

feet AGL, rather than the local barometric pressure or field altitude, before each flight.

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

91.121 is sought to the extent necessary to comply with the applicable conditions and 

limitations stated below. As more fully set forth herein, an equivalent level of safety will 

be maintained since the DJI Inspire 1 UAs are equipped with a barometric pressure

sensor and GPS equipment, which automatically ensures that a ground level pressure

setting will be established prior to each flight, and provides the PIC with altitude 

information of the UA on the heads-up display of the GCS.

4. Extent Of Relief Glennaire LLC Seeks And The Glennaire LLC 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 
14

Inspire 1UA s during daylight hours in visual meteorological conditions (VMC), under

visual flight rules (VFR), 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.

Glennaire LLC seeks the requested relief because without an exemption from Section

91.151(b), the flight time duration of the battery powered DJI Phantom 2 Inspire 1 UA 

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

that Glennaire LLC proposes to conduct pursuant to this Petition.

Significantly, as set forth below, the technical specifications of the DJI Phantom 2

Inspire 1 UAS, the DJI Inspire 1 operating documents, and Glennaire LLC’s proposed

operating limitations, ensure that Glennaire LLC will safely operate the battery powered

DJI Inspire 1 UAs during daylight hours in visual meteorological conditions (VMC), 

under visual flight rules (VFR), with enough battery power to fly for a total duration of 

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.

5. Extent Of Relief Glennaire LLC Seeks And The Reason Glennaire 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, Glennaire LLC requests relief from

these Sections because the DJI Inspire 1 UAS does not require airworthiness certificates.

As set forth more fully below, the DJI Inspire 1 UAS meets the conditions of FMRA 

Section 333 for operation without an airworthiness certificate. Accordingly, Glennaire 

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

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

UAS operating documents (i.e., the Glennaire LLC Aerial Operations Manual, Monthly

Maintenance Log, and DJI Inspire 1 Instruction Manual). Furthermore, Glennaire LLC
15

will document and maintain all maintenance records for the DJI Inspire 1 UAS.

D. The Reasons Why Granting Glennaire 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 Glennaire 

LLC to safely, efficiently, and economically perform aerial video and photography of 

apartment communities.

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 Glennaire 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 UA are battery powered and serve as a safe, efficient, and

economical alternative to the manned aircraft traditionally utilized to obtain aerial 

imagery. By reducing the amount of manned aircraft needed to perform aerial

acquisitions, an exemption allowing the use of a DJI Inspire 1 UAS would reduce the

amount of manned aircraft in the NAS, reduce noise and air pollution, as well as increase

the safety of life and property in the air and on the ground.

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

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

The DJI Inspire 1 UA does 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.
16

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 UA, 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 UA (weighing approximately 2 pounds 11 ounces and

6 pounds 7.5 ounces respectively, at their maximum gross weights with lengths of 16 

inches and 17.3 inches respectively, widths of 16 inches and 17.7 inches respectively, 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.
17

In addition to being safe and efficient, the DJI Inspire 1 is 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

Glennaire 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. 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 Glennaire 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, Glennaire LLC 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 Glennaire LLC Aerial Operations Manual,
18

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 Glennaire LLC Seeks Exemption.

1. Reasons Why The DJI Inspire 1UA 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, Glennaire LLC operation of the DJI 

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

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

Section 333 provides authority for a UAS to operate without airworthiness 

certification and sets forth requirements for considering whether a UAS will create a 

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

security. Specifically, FMRA Section 333 states the following, in part:

(a) In General.--Notwithstanding any other requirement of this subtitle, and 

not later than 180 days after the date of enactment of this Act, the

Secretary of Transportation shall determine if certain unmanned aircraft

systems may operate safely in the national airspace system before

completion of the plan

and rulemaking required by section 332 of this Act or the guidance required

by section 334 of this Act.

(b) Assessment of Unmanned Aircraft Systems.--In making the determination

under subsection (a), the Secretary shall determine, at a minimum--

(1) which types of unmanned aircraft systems, if any, as a result of their 

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

populated areas, and operation within visual line of sight do not

create a hazard to users of the national airspace system or the public

or pose a threat to national security; and
19

(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, Glennaire LLC submits that the DJI Phantom 2

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 1UAS 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 is set forth by the

DJI Inspire 1 Specifications and Data Sheet, attached here as Appendix A.

ii. The DJI Inspire 1 UAS Autonomous Flight And Navigation

Modes Enable The UAS To Remain Within A Defined 

Operational Area.

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

flight modes. A complete description of the flight and navigational modes of the DJI 

Inspire 1 UAS is provided at page 12 of the DJI Inspire 1 User Manual, attached as

Appendix B.

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.
20

When the Control Link is lost, the DJI Inspire 1 UA will remain stationary, in

flight, for 3 seconds or more. If, after 3 seconds, the DJI Inspire 1 UA does not reacquire

control link data from the GCS, the UA will assume that the Control Link is lost and the

UA 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 page 15 of the DJI Inspire 1 User Manual, attached as Appendix B.

iv. The DJI Inspire 1GCS And Its Operation.

A complete description of the operation and specifications of the

Inspire 1 GCS and flight control software is provided at pages 29 through 33 of the DJI 

Inspire 1 User Manual. DJI Inspire 1 User Manual is attached as Appendix B.

b. Flight Operations Of DJI Inspire 1 UAS Are Limited To The Line Of

Sight Of A Certificated Pilot in Command With A Safety Observer.

Glennaire LLC will only utilize certificated pilots who possess a current and 

valid airman medical certificate to act as a pilot in command (PIC) of the

Inspire 1 UAS. Additionally, a safety observer will assist all pilots during flight time.

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

Specific Operating Limitations.

In seeking this exemption, proposes to commercially operate DJI Phantom 2

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 UASs weighing less than 

55 pounds maximum gross weight: DJI Inspire 1 Unmanned Aircraft System.

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 
21

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 500 feet above ground level

(AGL), as indicated by the procedures specified in the operating documents unless a

special request is made and approved by ATC. All altitudes reported to ATC must

be in feet AGL.

5. The UAs must be operated within visual line of sight (VLOS) of the PIC at all 

times. This requires the PIC to be able to use human vision unaided by any device

other than corrective lenses, as specified on the PIC’s FAA-issued airman medical

certificate.

6. The use of first person view (FPV) by the PIC or safety observer (SO) is not 

permitted.

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

the VLOS requirement as long as the PIC always maintains VLOS capability. The

SO and PIC must be able to communicate verbally at all times. Electronic 

messaging or texting is not permitted during flight operations. The PIC must be 

designated before the flight and cannot transfer his or her designation for the 

duration of the flight. The PIC must ensure that the SO can perform the functions

prescribed in the operating documents.

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

and avoiding other air traffic and other ground based obstacles/obstructions and is

not permitted to operate the camera or other instruments.

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

UAS operations and made available to the Administrator upon request. If a 

discrepancy exists between the conditions and limitations contained in the grant of 

exemption and the procedures outlined in the operating documents, the conditions

and limitations contained in the grant of exemption take precedence and must be

followed. Otherwise, the operator must follow the procedures as outlined in its

operating documents. The operator may update or revise its operating documents.

It is the operator’s responsibility to track such revisions and present updated and

revised documents to the Administrator upon request. The operator must also

present updated and revised documents if it petitions for extension or amendment

to the grant of exemption. If the operator determines that any update or revision

would affect the basis upon which the FAA granted the exemption, then the

operator must petition for amendment to its grant of exemption. The FAA’s UAS 

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

or revisions to the operating documents.

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

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

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

necessary maintenance has been performed and the UAS is found to be in a 
22

condition for safe flight. The Ground Control Station must be included in the 

preflight inspection. All maintenance and alterations must be properly 

documented in the aircraft records.

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

operation or flight characteristics, e.g. replacement of a flight critical 

component, must undergo a functional test flight. The PIC who conducts the 

functional test flight must make an entry in the aircraft records.

12. The pre-flight inspection must account for all potential discrepancies, e.g. 

inoperable components, items, or equipment, not already covered in the 

relevant sections of the operating documents.

13. The operator must follow the UAS manufacturer’s aircraft/component, 

maintenance, overhaul, replacement, inspection, and life limit requirements.

14. The operator must carry out its maintenance, inspections, and record keeping 

requirements, in accordance with the operating documents. Maintenance, 

inspection, alterations, and status of replacement/overhaul component parts must be

noted in the aircraft records, including total time in service, description of work 

accomplished, and the signature of the authorized person returning the UAS to

service.

15. Each UASs 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 

third- class 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 nonparticipantsin 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.
23

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.

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 (N- Number) 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.
24

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.

Glennaire 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 Phantom 2 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 Glennaire LLC proposed area of operations, and the operating 
25

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, Glennaire LLC

submits that the additional manned airmanship experience of a commercially certificated

pilot would not correlate to the airmanship skills necessary for Glennaire LLC 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).

Glennaire 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 
26

equivalent level of safety during Glennaire LLC 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 flighthour requirements in Exemption No. 11062 are appropriate to practice and build

proficiency in the skills necessary to safely conduct the petitioner’s proposed

operations. The FAA also finds that prior documented flight experience that was

obtained in compliance with applicable regulations would satisfy this

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

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

During training, proficiency, and experience-building flights the PIC is required to
27

operate the UA with appropriate distances in accordance with 14 C.F.R 91.119. 

Exemption No. 11138 at page 25.

Accordingly, Glennaire 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, Glennaire LLC will ensure that the DJI 

Phantom 2 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 UA 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 
28

information, combined with Glennaire LLC’s operation of the DJI Phantom 2

Inspire 1 UA 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 UASs at ground level.

The FAA has previously granted relief from Section 91.121 specific to UAS, in 

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

Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11112, 

11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161).

5. Reasons Why An Exemption From The Requirements Of Section

91.151(b) Would Not Adversely Affect Safety.

A grant of this exemption would ensure an equivalent level of safety established by

14 C.F.R. Section 91.151(b) as a result of (1) the technical specifications of the DJI

Inspire 1 UAs; (2) the limitations on the proposed flight operations; and (3) the location

of the proposed flight operations. Accordingly, Glennaire LLC will ensure that it will

safely operate the battery powered DJI Inspire 1 UA 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.

Here, as in Exemption No. 11109, the technical specifications of the DJI Phantom 2

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
29

again at approximately 10% remaining battery power. At the critically low battery level, 

the DJI Phantom 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, Glennaire 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 Glennaire 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 Glennaire LLC Aerial

Operations Manual, Monthly Maintenance Log, and DJI Inspire 1 Instruction Manual). 

Furthermore, Glennaire 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, Glennaire LLC will maintain the equivalent level of safety established by

Sections 91.405(a), 91.409(a)(1), and 91.409(a)(2). A copy of the DJI Inspire 1 User
30

Manuals are attached as Appendix B; a copy of the DJI Inspire 1 UAS Maintenance

LOG is attached as Appendix C.

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

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 Glennaire LLC proposed operating limitations, the 

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

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.
31

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, Glennaire LLC requests 

that the FAA prescribe special conditions for the intended operation of the DJI Phantom 2

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

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

H, and 14 C.F.R §§ 61.113(a) & (b), 91.7 (a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1),

91.409(a)(1) & (a)(2), and 91.417(a) & (b). Such special conditions will permit safe 

operation of the UAs for the limited purpose of conducting aerial video and photography 

over certain areas of the United States for compensation or hire. FMRA Section 333 sets 

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

NAS or the public, or otherwise pose a threat to national security; and further, provides

the authority for such UAS to operate without airworthiness certification in accordance

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

NAS.

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

§ 21.16, for operation of the DJI Inspire 1 UAS, since the airworthiness regulations of 

14 C.F.R. Part 21 do not contain adequate or appropriate safety standards, due to the

novel or unusual design features of the aircraft. Section 21.16, entitled Special 

Conditions, states the following:

If the FAA finds that the airworthiness regulations of this subchapter do not

contain adequate or appropriate safety standards for an aircraft, aircraft engine, or 

propeller because of a novel or unusual design feature of the aircraft, aircraft

engine or propeller, he prescribes special conditions and amendments thereto for 

the product. The special conditions are issued in accordance with Part 11 of this

chapter and contain such safety standards for the aircraft, aircraft engine or 

propeller as the FAA finds necessary to establish a level of safety equivalent to

that established in the regulations.

See 14 C.F.R. § 21.16.
32

Therefore, in accordance with FMRA Section 333 and 14 C.F.R. § 21.16, the

FAA may prescribe special conditions for LEDIC’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).

F. A Summary That Can Be Published In The Federal Register, stating: The Rules

From Which Glennaire LLC Seeks Exemption:

Glennaire 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 Glennaire LLC 

Seeks:

This exemption will permit Glennaire 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, with particular focus 

on apartment communities.

G. Any Additional Information, Views, Or Arguments Available To Support

Glennaire LLC 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, Glennaire LLC 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.
33

As discussed in detail above, Glennaire LLC will operate the DJI Phantom 2

Inspire 1 UASs safely in the NAS, without creating a hazard to users of the NAS, or 

the public, or otherwise pose a threat to national security.
34

CONCLUSION

As set forth herein, Glennaire 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

Glennaire LLC to safely, efficiently, and economically operate the DJI Inspire 1UAS 

commercially within the NAS.

WHEREFORE, in accordance with the Federal Aviation Regulations and the

FAA Modernization and Reform Act of 2012, Section 333, Glennaire 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 LEDIC to operate the DJI 

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

photography over certain areas of the United States.

Dated: September 13, 2015

Respectfully submitted, 

Albert Glenn

Glennaire LLC

5061 LeChateau Cove

Memphis TN 38125

Tel (901) 647-4211

glennaireuav@gmail.com
35

Appendices:

A – DJI Inspire 1 Specifications Data Sheet

B – DJI Inspire 1 Manufacturer’s User Manual

C – Monthly Maintenance Log

APPENDIX – A

DJI INSPIRE 1 TECHNICAL SPECIFICATIONS

Glennaire LLC 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)

1.1 DJI Phantom 2 Inspire 1

1.1.1 Aircraft

1.1.1.1 Supported Battery – DJI 5200mAH LiPo Battery

1.1.1.2 Weight (Battery & Propellers Included) – 2lbs 11.810oz (1242g)

1.1.1.3 Hover Accuracy (Ready to Fly) – Vertical: .8m; Horizontal: 2.5m

1.1.1.4 Max Yaw Angular Velocity - 2000/s

1.1.1.5 Max Tilt Angel - 350

1.1.1.6 Max Ascent Speed – 6m/s

1.1.1.7 Max Descent Speed – 2m/s

1.1.1.8 Max Flight Speed – 15m/s (NOT RECOMMENDED)

1.1.2 Gimbal

1.1.2.1 Working Current – Static: 750mA; Dynamic: 900mA

1.1.2.2 Control Accuracy - ±0.03°

1.1.2.3 Controllable Range – Pitch: -90° - 0°

1.1.2.4 Maximum Angular Speed – Pitch: 90°/s

1.1.3 Camera

1.1.3.1 Operating Temperature Range - 32°F - 104°F (0°C - 40°C)

1.1.3.2 Sensor Size – 1/2.3”

1.1.3.3 Effective Pixels – 14M

1.1.3.4 Resolution – 4384x3288

4.1.3.5 HD Video Recording – 1080p30 & 720p

4.1.3.6 Recording Field of View - 110°/85°

1.1.4 Transmitter

1.1.4.1 Operating Frequency – 5.728GHz – 5.85GHz

1.1.4.2 Communication Distance (unobstructed) – FCC Compliance: 800m

1.1.4.3 Receiver Sensitivity (1%PER) - -93dBm
36

1.1.4.4 Transmitter Power – FCC Compliance: 100mW

1.1.4.5 Working Voltage – 120mA@3.7V

1.1.5 Range Extender

1.1.5.1 Operating Frequency – 2412-2462MHz

1.1.5.2 Communication Distance (unobstructed) – 500-700m

1.1.5.3 Transmitter Power – 20dBm

1.1.5.4 Power Consumption – 2W
37

APPENDIX - B

DJI Inspire 1 Manufacturer’s User Manual

All referenced pages are enclosed on separate document, attached as Inspire 1 User Manual 

(2015.3).

 Complete description of the flight and navigational modes of the DJI Inspire 1 UAS

– page 12

 Complete description of the Failsafe Functions of the DJI Inspire 1 UAS – page 15

 Complete description of the operation and specifications of the Inspire 1 GCS and

flight control software – pages 29-33
38

APPENDIX – C

MONTHLY MAINTENANCE

LOG Month: Year:

UAS: Date Issue

Discovered

Date Issue

Addressed Issue Description & Maintenance Conducted

Maintenance Performed By:

Print & Sign

Software Updates

Airframe

Engines

Propellers

Camera Gimbal

Landing Gear

Vibration Dampening

Other: