UNITED STATES OF AMERICA 

DEPARTMENT OF TRANSPORTATION 

FEDERAL AVIATION ADMINISTRATION 

WASHINGTON, DC 

Regulatory Docket No. _______________ 

IN THE MATTER OF THE PETITION FOR EXEMPTION OF:

GARY BREVIG

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 1UNMANNED AIRCRAFT SYSTEMS

PURSUANT TO SECTION 333 OF

THE FAA MODERNIZATION AND REFORM ACT OF 2012 (PUBLIC 

LAW 112-95)
Submitted on May 5, 2015

GARY BREVIG

11090 183rd Cir NW

Elk River MN 55330

952-278-2402

Garyb@DennisonTech.com

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 GARY BREVIG

SEEKS EXEMPTION........................................................................8 

THE EXTENT OF RELIEF GARY BREVIG SEEKS AND THE REASON 

GARY BREVIG SEEKS THE RELIEF.......................................12 

THE REA SONS WHY GRANTING GARY BREVIG’S REQUEST 

WOULD BE IN THE PUBLIC INTEREST .........................................................15 

THE REASONS WHY GRANTING THE EXEMPTION WOULD NOT 

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

 

SUMMARY THAT CAN BE PUBLISHED IN THE FEDERAL REGISTER.............33 

 

ANY ADDITIONAL INFORMATION, VIEWS, OR ARGUMENTS 

AVAILABLE TO SUPPORT GARY BREVIG’S REQUEST............34 

CONCLUSION ................................................................................................................... 35 

APPENDICES........................................................................................36 

GLOSSARY OF ABBREVIATIONS

AGL Above Ground Level NAS National Airspace System 

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 

MSL Mean Sea Level 

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 Sight 

VMC Visual Meterological 

Conditions 

VTOL Vertical Takeoff and 

Landing

SUMMARY

Gary Brevig 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 Gary Brevig to operate an Unmanned Aircraft System (UAS) for the commercial 

purpose of conducting aerial video and photography of construction sites, real estate, 

farmland, and landscape over certain areas of the United States. 

INTRODUCTION AND INTERESTS OF THE PETITIONER

Gary Brevig provides his clients with expertise and knowledge in advanced technologies 

and solutions to increase efficiency, productivity and effectiveness. Gary Brevig is an 

instrument rated pilot with nearly 100 hours of flying experience. He has over 10 years 

recreational/hobby experience in all aspects of aerial video and photography. The objective 
of Gary Brevig and his aerial operations is to safely provide high quality imaging for a 

variety of commercial, public, and residential uses, specifically targeting: 

• Agriculture 

• General aerial still photos 

• Wildlife population surveys 

• Real Estate marketing 

• Motion Picture Filming 

• Aerial inspections of public and private 

 Structures. 

• Search and Rescue operations 

BACKGROUND

 Unmanned Aircraft Systems: DJI Inspire 1UASs

Gary Brevig seeks an exemption to operate DJI systems for compensation or hire within 

the NAS. The DJI Inspire 1is 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 1has a maximum gross weight of approximately 2936 g with 

battery, while total measurements are 438x461x301mm, and a maximum speed of 

approximately 22m/s. The DJI Inspire 1UA is equipped with four main rotors, driven by

Lithium Polymer battery powered electric motors. 

The DJI Inspire 1UA that will be operated by Gary Brevig 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, Gary Brevig, 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 

1UA 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, Gary Brevig’s operation of the DJI Inspire 1UA 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, Gary Brevig 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. 

Gary Brevig submits that the requested relief is proper since an equivalent level of safety 

will be ensured. Gary Brevig 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, Gary Brevig will 

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

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

Privileges and Limitations: Pilot in Command, is requested by Gary Brevig 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 1UA in a manner consistent with this exemption, including evasive and 

emergency maneuvers and maintaining appropriate distances from people, vessels, 

vehicles, and structures. 

Gary Brevig seeks relief from Section 91.7(a), entitled Civil Aircraft Airworthiness, 

because the DJI Inspire 1UA does not require an airworthiness certificate in accordance 

with 14 C.F.R. Part 21, Subpart H. As such, Gary Brevig submits that he will ensure that 

the DJI Inspire 1UA is in an airworthy condition, prior to every flight, by determining that 

the UA is in compliance with the operating documents (i.e., Monthly Maintenance Log, 

and DJI Inspire 1Instruction Manual), and that the aircraft is in a condition for safe flight. 

Gary Brevig also seeks an exemption from the requirements of Section 91.121, entitled 

Altimeter Settings, as the DJI Inspire 1UA will not have a typical barometric altimeter 

onboard. However, altitude information of the DJI Inspire 1UA 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 Gary Brevig’s operation of the DJI Inspire 1UA 

within visual line of sight, at or below 

500 feet AGL, will ensure a level of safety equivalent to Section 91.121. 

Additionally, Gary Brevig seeks an exemption from the requirements of 

Section 91.151(b), entitled Fuel Requirements for Flight in VFR Conditions. Gary Brevig

submits that safety will not be affected by operation of the DJI Inspire 1UA 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 12.5 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, Gary Brevig provides the following 

information in support of his petition for exemption: 

Name And Address Of The Petitioner.

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

GARY BREVIG

11090 183rd Cir NW

Elk River MN 55330

952-278-2402

Garyb@DennisonTech.com

 
The Specific Sections Of 14 C.F.R. From Which Gary Brevig Seeks Exemption.

1. Gary Brevig 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. Gary Brevig 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. Gary Brevig Seeks Exemption From The Requirements Of Section 

91.121. 

Section 91.121, entitled Altimeter Settings, subsection (a), states the following, in 

part: 

(a) Each person operating an aircraft shall maintain the cruising altitude or 

flight level of that aircraft, as the case may be, by reference to an altimeter that 

is set, when operating--

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

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

Within 100 nautical miles of the aircraft; 

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

of this section, the current reported altimeter setting of an appropriate 

available station; or 

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

the departure airport or an appropriate altimeter setting available 

before departure. 

4. Gary Brevig 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. Gary Brevig Seeks Exemption From The 

Requirement Of Section 91.405(a).

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

owner or operator of an aircraft—

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

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

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

6. Gary Brevig 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. Gary Brevig 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. Gary Brevig Seeks Exemption From The Requirements Of Sections 

91.417(a) And 91.417(b). 

Section 91.417, entitled Maintenance Records, subsections (a) and (b), state the 

following: 

(a) Except for work performed in accordance with §§ 91.411 and 91.413, each

registered owner or operator shall keep the following records for the periods 

specified in paragraph (b) of this section: 

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

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

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

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

include--

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

of the work performed; and 

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

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

aircraft for return to service. 

(2) Records containing the following information: 

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

propeller, and each rotor. 
(ii) The current status of life-limited parts of each airframe, 

engine, propeller, rotor, and appliance. 

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

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

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

time since the last inspection required by the inspection program under 

which the aircraft and its appliances are maintained. 

(v) The current status of applicable airworthiness directives 

(AD) and safety directives including, for each, the method of 

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

AD or safety directive involves recurring action, the time and date 

when the next action is required. 

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

for each major alteration to the airframe and currently installed 

engines, rotors, propellers, and appliances. 

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

prescribed: 

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

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

after the work is performed. 

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

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

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

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

aircraft is approved for return to service. 
The Extent Of Relief And The Reason Gary Brevig Seeks The Relief.

1. Extent of Relief Gary Brevig Seeks And The Reason 

Gary Brevig 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, Gary Brevig submits that an equivalent level of safety will 

be maintained because no PIC will be allowed to operate the DJI Inspire 1UA unless that 

PIC has met certain flight-hour and currency requirements, demonstrating that the PIC is 

able to safely operate either the DJI Inspire 1UA 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, Gary Brevig submits that all flights of the DJI Inspire 1UA, conducted by the PIC 

pursuant to the grant of this Petition: (1) will be incidental to 

Gary Brevig’s business; and (2) will not carry passengers or property for compensation or 

hire. 

2. Extent Of Relief Gary Brevig Seeks And The Reason Gary Brevig 

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 Gary Brevig to determine that the DJI Inspire 1UA is in airworthy

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

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

Manual). 
Gary Brevig seeks the requested relief because the DJI Inspire 1UA does not require an 

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

Brevig will ensure that the DJI Inspire 1UA is in airworthy condition based upon its 

compliance with the operating documents (i.e., Monthly Maintenance Log, and DJI Inspire 

1Instruction Manual) prior to every flight, and further, determine that the aircraft is in 

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

3. Extent of Relief Gary Brevig Seeks And The Reason Gary

BrevigSeeks Relief From Section 91.121.

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

operations of the DJI Inspire 1UA, which utilizes 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), Gary Brevig 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 1UA is 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 Gary Brevig Seeks And The Reason Gary Brevig 

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 1UA 

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. Gary Brevig seeks 

the requested relief because without an exemption from Section 

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

Constrain the practicality of any aerial video or still photo flight operations that Gary

Brevig proposes to conduct pursuant to this Petition. 
Significantly, as set forth below, the technical specifications of the DJI Inspire 1UA, the 

DJI Inspire 1and Gary Brevig’s proposed operating limitations, ensure that Gary Brevig 

will safely operate the battery powered DJI Inspire 1UA 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 Gary Brevig Seeks And The Reason 

Gary Brevig 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, Gary Brevig requests relief from these 

Sections because the DJI Inspire 1UA 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, Gary Brevig 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 Monthly Maintenance Log, and DJI Inspire 1Instruction Manual). 

Furthermore, Gary Brevig will document and maintain all maintenance records for the DJI 

Inspire 1UAS. 

The Reasons Why Granting Gary Brevig’s 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 

Gary Brevig to safely, efficiently, and economically perform aerial video and 

photography of construction sites, real estate, and landscape over certain areas of the 

United States and assist area first responders. 

Additionally, use of the DJI Inspire 1UAS will decrease congestion of the NAS, reduce 

pollution, and provide significant benefits to the economy. Notably, the benefits of Gary

Brevig’s proposed operation of the DJI Inspire 1UAS will be realized without implicating 

any privacy issues. 

1. The Public Will Benefit From Decreased Congestion Of The NAS.
The DJI Inspire 1UA is battery powered and serves as a safe, efficient, and economical 

alternative to the manned aircraft traditionally utilized to obtain aerial imagery. By

reducing the number of manned aircraft needed to perform aerial acquisitions, an 

exemption allowing the use of a DJI Inspire 1UAS would reduce the number of manned 

aircraft in the NAS and 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 

1UA 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 1UAS.

Conducting aerial acquisitions with the DJI Inspire 1UAS, 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 1UAS 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 1UA, 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 1UAS 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 

1UA (weighing approximately 2 pounds 11 ounces at its maximum gross weight with a 

length of 16 inches and widths of 16 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 1UAS Will Benefit The Economy.

In addition to being safe and efficient, the DJI Inspire 1UA is also an economical 

alternative to using manned aircraft to conduct similar aerial operations. As such, operation 

of the DJI Inspire 1UAS will allow United States based companies, like Gary Brevig, 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 1UAS 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 1UAS, companies such as Gary Brevig “Dennison 

Technology Group”, 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 1UAS, 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, Gary Brevig’s proposed operation of the DJI Inspire 1UAS will not implicate any

privacy issues. Specifically, the DJI Inspire 1UAS will be operated only in compliance 

with operating documents (i.e., The Monthly Maintenance Log, and DJI Inspire 

1Instruction 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. 
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 Gary Brevig Seeks Exemption.

1. Reasons Why The DJI Inspire 1UA Meets 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, Gary Brevig’s operation of the DJI Inspire 1UAS 
meets the conditions of FMRA Section 333, and will not require an airworthiness 

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

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

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

NAS or the public, or otherwise pose a threat to national security. Specifically, FMRA 

Section 333 states the following, in part: 

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

later than 180 days after the date of enactment of this Act, the Secretary of 

Transportation shall determine if certain unmanned aircraft systems may 

operate safely in the national airspace system before completion of the plan 

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

section 334 of this Act. 

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

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

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

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

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

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

threat to national security; and

(2) Whether a certificate of waiver, certificate of authorization, or 

airworthiness certification under section 44704 of title 49, United States 

Code, is required for the operation of unmanned aircraft systems 

identified under paragraph (1).

(c) Requirements for Safe Operation.--If the Secretary determines under this 

section that certain unmanned aircraft systems may operate safely in the 

national airspace system, the Secretary shall establish requirements for the safe 

operation of such aircraft systems in the national airspace system.
In seeking this exemption, Gary Brevig submits that the DJI Inspire 1UAS can operate 

safely in the NAS pursuant to FMRA Section 333, as demonstrated by: (a) the 

characteristics of the DJI Inspire 1UA; (b) the pilot certification requirement; and (c) the 

specific operating limitations. 

a. The Specifications Of The DJI Inspire 1UAS Demonstrates 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 1UAS

The technical specifications of the DJI Inspire 1UAS are set forth by the DJI Inspire 1

User Manual, attached here to as Appendix A. 

ii. The DJI Inspire 1UAS Autonomous Flight And Navigation 

Modes Enable The UAS To Remain Within A Defined 

Operational Area.

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

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

1UAS is provided at pages 25-35 of the DJI Inspire 1User Manual, attached hereto as 

Appendix A. 

iii. The DJI Inspire 1UAS Are Designed For Automatic Return 

To Home Point Or Hover In The Event Of Loss Of The Control 

Link Or Navigation.

When the Control Link is lost, the DJI Inspire 1UA will remain stationary, in flight, for 3 

seconds or more. If, after 3 seconds, the DJI Inspire 1UA 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 Function of the DJI Inspire 1UAS is set forth at 

pages 27 through 29 of the DJI Inspire 1User Manual, attached hereto as Appendix A. 

iv. The DJI Inspire 1GCS And Its Operation.

A complete description of the operation and specifications of the DJI Inspire 1GCS and 

flight control software is provided at pages 32 through 43 of the DJI Inspire 1User 

Manual. DJI Inspire 1User Manuals are attached hereto as Appendix A. 

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

Of Sight of a Certificated Pilot in Command with a Safety Observer.

Gary Brevig will be the only person to act as a pilot in command (PIC) of the DJI Inspire 

1UAS. Additionally, a safety observer will assist him during flight time. 

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

Specific Operating Limitations.

In seeking this exemption, Gary Brevig proposes to commercially operate DJI Inspire 

1UAS for the special purpose of conducting aerial video and photography over certain 

areas of the 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 

1Unmanned 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 for the purpose of aerial video and photography. 

3. The UA 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 UA must be operated within visual line of sight (VLOS) of the PIC at 

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

any device other than corrective lenses, as specified on the PIC’s FAAissued airman medical certificate. 

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

permitted. 

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

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

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

times. 

Electronic messaging or texting is not permitted during flight operations. The 

PIC must be designated before the flight and cannot transfer his or her 

designation for the duration of the flight. The PIC must ensure that the SO 

can perform the functions prescribed in the operating documents. 

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

seeing and avoiding other air traffic and other ground based 

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

instruments. 

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

during UAS operations and made available to the Administrator upon 

request. If a discrepancy exists between the conditions and limitations 

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

operating documents, the conditions and limitations contained in the grant 
of exemption take precedence and must be followed. Otherwise, the 

operator must follow the procedures as outlined in its operating documents. 

The operator may update or revise its operating documents. It is the 

operator’s responsibility to track such revisions and present updated and 

revised documents to the Administrator upon request. The operator must 

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

amendment to the grant of exemption. If the operator determines that any 

update or revision would affect the basis upon which the FAA granted the 

exemption, then the operator must petition for amendment to its grant of 

exemption. The FAA’s UAS Integration Office (AFS-80) may be contacted 

if questions arise regarding updates or revisions to the operating documents. 

 

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

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

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

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

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

the preflight inspection. All maintenance and alterations must be properly 

documented in the aircraft records. 

 

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

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

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

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

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

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

relevant sections of the operating documents. 

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

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

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

keeping requirements, in accordance with the operating documents. 
Maintenance, inspection, alterations, and status of replacement/overhaul 

component parts must be noted in the aircraft records, including total time 

in service, description of work accomplished, and the signature of the 

authorized person returning the UAS to service. 

15. Each UAS operated under this exemption must comply with all 

manufacturer Safety Bulletins. 

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

corrective action taken against discrepancies discovered between 

inspections. 

17. The 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 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 

pre-determined 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. 

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.

Gary Brevig 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 1UAS 

unless that PIC has demonstrated, by meeting minimum flight hour and currency

requirements, that the PIC is able to safely operate the DJI Inspire 1UAS in a manner 

consistent with the exemption, including evasive and emergency maneuvers and 

maintaining appropriate distances from people, vessels, vehicles, and structures. 
Considering Gary Brevig’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 1UAS, Gary Brevig submits that the 

additional manned airmanship experience of a commercially certificated pilot would not 

correlate to the airmanship skills necessary for Gary Brevig’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). 

Gary Brevig will not allow any PIC to operate the DJI Inspire 1UAS unless that PIC has 

demonstrated, by meeting minimum flight-hour requirements or the DJI Inspire 1UAS 

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

1UAS 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 Gary Brevig’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, 

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. 

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, Gary Brevig will ensure that the DJI Inspire 1UAS is in an airworthy 

condition based upon the UAS’ 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 1UA 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 Gary Brevig’s operation of the DJI Inspire 1UA 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 

1UAS; (2) the limitations on the proposed flight operations; and (3) the location of the 

proposed flight operations. Accordingly, Gary Brevig will ensure that it will safely operate 

the battery-powered DJI Inspire 1UA 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 Inspire 1UAS, 

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 1UAS provides audible 

and visual warnings to the PIC at the GCS when the UA 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 1UAS 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, Gary Brevig 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 

Gary Brevig will use trained technicians to perform maintenance, alterations, or preventive 

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

operating documents (i.e. The Monthly Maintenance Log and DJI Inspire 1Instruction 

Manual). Furthermore, Gary Brevig will document and maintain all maintenance records 

for the DJI Inspire 1UAS. 

Since the DJI Inspire 1UAS will be inspected as prescribed by the operating documents, 

Gary Brevig 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 1User Manual is attached hereto 

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

Appendix B. 

Likewise, the exemption sought will not adversely affect safety because Gary Brevig 

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 1UAS 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 Gary Brevig’s proposed operating limitations, the operating documents, 

and the technical aspects of the DJI Inspire 1UAS, Gary Brevig 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, Gary Brevig requests that the 

FAA prescribe special conditions for the intended operation of the DJI Inspire 1UAS, 

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 UA 

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 1UAS, since the airworthiness regulations 

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

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

Conditions, states the following: 

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

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

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

propeller, he prescribes special conditions and amendments thereto for the product. 

The special conditions are issued in accordance with Part 11 of this chapter and 

contain such safety standards for the aircraft, aircraft engine or propeller as the 

FAA finds necessary to establish a level of safety equivalent to that established in 

the regulations. 

See 14 C.F.R. § 21.16. 

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

prescribe special conditions for Leading Edge’s intended operation of the DJI Inspire 

1UAS, 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 Gary Brevig Seeks 

Exemption:
Gary Brevig 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 Gary Brevig Seeks:

This exemption will permit GaryBrevig 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 Gary Brevig’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, Gary Brevig’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, Gary Brevig will operate the DJI Inspire 1UAS 

safely in the NAS, without creating a hazard to users of the NAS, or the public, 

or otherwise pose a threat to national security. 

Listed in Appendix C is a link to a brief article outlining the environmental benefits of 

commercial use of a UAS. 
CONCLUSION

As set forth herein, Gary Brevig 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 1UAS 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 Gary Brevig 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, Gary Brevigrespectfully

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 Gary Brevig to operate the DJI 

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

over certain areas of the United States. Dated: May 27th, 2015 

Respectfully submitted, 

_________________________ 

GARY BREVIG

11090 183rd Cir NW

Elk River MN 55330 

952-278-2402

Garyb@DennisonTech.com
Apendix

A. DJI Inspire 1 User Manual Attached

B. Proposed Maintenance Log 

C. Link to a Supportive Article http://rotordronemag.com/can-drones-saveplanet/

Service Date 

Aircraft 

Hours Items performed Items Needing Attention