April 8, 2015

 Exemption No. 11303

 Regulatory Docket No. FAA−2014−1019

Mr. Martin Lovelady

TradeCraft, LLC

7090 Pale Down Place SE

Owens Cross Roads, AL 35763

Dear Mr. Lovelady:

This letter is to inform you that we have granted your request for exemption. It transmits our 

decision, explains its basis, and gives you the conditions and limitations of the exemption, 

including the date it ends.

The Basis for Our Decision

By letter dated December 6, 2014, you petitioned the Federal Aviation Administration (FAA) 

on behalf of TradeCraft, LLC (hereinafter petitioner or operator) for an exemption. The 

exemption would allow the petitioner to operate an unmanned aircraft system (UAS) to 

conduct agriculture, aerial surveying, and imagery operations.

See Appendix A for the petition submitted to the FAA describing the proposed operations and 

the regulations that the petitioner seeks an exemption.

The FAA has determined that good cause exists for not publishing a summary of the petition 

in the Federal Register because the requested exemption would not set a precedent, and any 

delay in acting on this petition would be detrimental to the petitioner.

Airworthiness Certification

The UAS proposed by the petitioner is a DJI Inspire 1.
2

The petitioner requested relief from 14 CFR part 21, Certification procedures for products 

and parts, Subpart H—Airworthiness Certificates. In accordance with the statutory criteria 

provided in Section 333 of Public Law 112−95 in reference to 49 U.S.C. § 44704, and in 

consideration of the size, weight, speed, and limited operating area associated with the 

aircraft and its operation, the Secretary of Transportation has determined that this aircraft 

meets the conditions of Section 333. Therefore, the FAA finds that the requested relief from 

14 CFR part 21, and any associated noise certification and testing requirements of part 36, is 

not necessary.

The Basis for Our Decision

You have requested to use a UAS for aerial data collection. The FAA has issued grants of 

exemption in circumstances similar in all material respects to those presented in your petition. 

In Grants of Exemption Nos. 11062 to Astraeus Aerial (see Docket No. FAA−2014−0352), 

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

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

FAA−2014−0642), the FAA found that the enhanced safety achieved using an unmanned 

aircraft (UA) with the specifications described by the petitioner and carrying no passengers or 

crew, rather than a manned aircraft of significantly greater proportions, carrying crew in 

addition to flammable fuel, gives the FAA good cause to find that the UAS operation enabled 

by this exemption is in the public interest.

Having reviewed your reasons for requesting an exemption, I find that—

• They are similar in all material respects to relief previously requested in Grant of 

Exemption Nos. 11062, 11109, 11112, and 11213;

• The reasons stated by the FAA for granting Exemption Nos. 11062, 11109, 11112, and 

11213 also apply to the situation you present; and 

• A grant of exemption is in the public interest.

Our Decision

In consideration of the foregoing, I find that a grant of exemption is in the public interest. 

Therefore, pursuant to the authority contained in 49 U.S.C. 106(f), 40113, and 44701, 

delegated to me by the Administrator, TradeCraft, LLC is granted an exemption from 14 CFR 

§§ 61.23(a) and (c), 61.101(e)(4) and (5), 61.113(a), 61.315(a), 91.7(a), 91.119(c), 91.121, 

91.151(a)(1), 91.405(a), 91.407(a)(1), 91.409(a)(1) and (2), and 91.417(a) and (b), to the 

extent necessary to allow the petitioner to operate a UAS to perform aerial data collection. 

This exemption is subject to the conditions and limitations listed below.

Conditions and Limitations

In this grant of exemption, TradeCraft, LLC is hereafter referred to as the operator.
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Failure to comply with any of the conditions and limitations of this grant of exemption will be 

grounds for the immediate suspension or rescission of this exemption.

1. Operations authorized by this grant of exemption are limited to the DJI Inspire 1 when 

weighing less than 55 pounds including payload. Proposed operations of any other 

aircraft will require a new petition or a petition to amend this exemption.

2. Operations for the purpose of closed-set motion picture and television filming are 

not permitted. 

3. The UA may not be operated at a speed exceeding 87 knots (100 miles per hour). The 

exemption holder may use either groundspeed or calibrated airspeed to determine 

compliance with the 87 knot speed restriction. In no case will the UA be operated at 

airspeeds greater than the maximum UA operating airspeed recommended by the 

aircraft manufacturer.

4. The UA must be operated at an altitude of no more than 400 feet above ground level 

(AGL). Altitude must be reported 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 FAA-issued airman medical certificate or 

U.S. driver’s license.

6. All operations must utilize a visual observer (VO). The UA must be operated within 

the visual line of sight (VLOS) of the PIC and VO at all times. The VO may be used 

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

capability. The VO 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 VO can perform the duties 

required of the VO.

7. This exemption and all documents needed to operate the UAS and conduct its 

operations in accordance with the conditions and limitations stated in this grant of 

exemption, are hereinafter referred to as the operating documents. The operating 

documents must be accessible during UAS operations and made available to the 

Administrator upon request. If a discrepancy exists between the conditions and 

limitations in this exemption and the procedures outlined in the operating documents, 

the conditions and limitations herein 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 or any law enforcement official upon request. The 
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operator must also present updated and revised documents if it petitions for extension 

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

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

operator must petition for an 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.

8. 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 prior to conducting further operations under this exemption. 

Functional test flights may only be conducted by a PIC with a VO and must remain at 

least 500 feet from other people. The functional test flight must be conducted in such 

a manner so as to not pose an undue hazard to persons and property.

9. The operator is responsible for maintaining and inspecting the UAS to ensure that it is 

in a condition for safe operation.

10. Prior to each flight, the PIC must conduct a pre-flight inspection and determine the 

UAS is in a condition for safe flight. The pre-flight inspection must account for all 

potential discrepancies, e.g. inoperable components, items, or equipment. 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.

11. The operator must follow the UAS manufacturer’s maintenance, overhaul, 

replacement, inspection, and life limit requirements for the aircraft and aircraft 

components.

12. Each UAS operated under this exemption must comply with all manufacturer safety 

bulletins.

13. Under this grant of exemption, a PIC must hold either an airline transport, 

commercial, private, recreational, or sport pilot certificate. The PIC must also hold a 

current FAA airman medical certificate or a valid U.S. driver’s license issued by a 

state, the District of Columbia, Puerto Rico, a territory, a possession, or the Federal 

government. The PIC must also meet the flight review requirements specified in 

14 CFR § 61.56 in an aircraft in which the PIC is rated on his or her pilot certificate.

14. The operator may not permit any PIC to operate unless the PIC demonstrates the 

ability to safely operate the UAS in a manner consistent with how the UAS will be 

operated under this exemption, including evasive and emergency maneuvers and 

maintaining appropriate distances from persons, vessels, vehicles and structures. PIC 

qualification flight hours and currency must be logged in a manner consistent with 

14 CFR § 61.51(b). Flights for the purposes of training the operator’s PICs and VOs 
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(training, proficiency, and experience-building) and determining the PIC’s ability to 

safely operate the UAS in a manner consistent with how the UAS will be operated 

under this exemption are permitted under the terms of this 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 CFR § 91.119.

15. UAS operations may not be conducted during night, as defined in 14 CFR § 1.1. All 

operations must be conducted under visual meteorological conditions (VMC). Flights 

under special visual flight rules (SVFR) are not authorized.

16. The UA may not operate within 5 nautical miles of an airport reference point (ARP) as 

denoted in the current FAA Airport/Facility Directory (AFD) or for airports not 

denoted with an ARP, the center of the airport symbol as denoted on the current FAApublished aeronautical chart, unless a letter of agreement with that airport’s 

management is obtained or otherwise permitted by a COA issued to the exemption 

holder. The letter of agreement with the airport management must be made available 

to the Administrator or any law enforcement official upon request.

17. 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.

18. If the UAS loses communications or loses its GPS signal, the UA must return to a predetermined location within the private or controlled-access property.

19. The PIC must abort the flight in the event of unpredicted obstacles or emergencies.

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

weather conditions) there is enough available power for the UA to conduct the 

intended operation and to operate after that for at least five minutes or with the reserve 

power recommended by the manufacturer if greater.

21. Air Traffic Organization (ATO) Certificate of Waiver or Authorization (COA). All 

operations shall be conducted in accordance with an ATO-issued COA. The 

exemption holder may apply for a new or amended COA if it intends to conduct 

operations that cannot be conducted under the terms of the attached COA.

22. All aircraft operated in accordance with this exemption must be identified by serial 

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

as large as practicable.
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23. Documents used by the operator to ensure the safe operation and flight of the UAS and 

any documents required under 14 CFR §§ 91.9 and 91.203 must be available to the 

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

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

official upon request.

24. The UA must remain clear and give way to all manned aviation operations and 

activities at all times. 

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

26. All Flight operations must be conducted at least 500 feet from all nonparticipating 

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 in a manner ensuring the safety 

of nonparticipating persons; and

b. The owner/controller of any vessels, vehicles or structures has granted permission 

for operating closer to those objects 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.

The PIC, VO, operator trainees or essential persons are not considered 

nonparticipating persons under this exemption.

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

permission from the property owner/controller or authorized representative. 

Permission from property owner/controller or authorized representative will be 

obtained for each flight to be conducted.

28. 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.

If this exemption permits operations for the purpose of closed-set motion picture and 

television filming and production, the following additional conditions and limitations apply.

29. The operator must have a motion picture and television operations manual (MPTOM) 

as documented in this grant of exemption.
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30. At least 3 days before aerial filming, the operator of the UAS affected by this 

exemption must submit a written Plan of Activities to the local Flight Standards 

District Office (FSDO) with jurisdiction over the area of proposed filming. The 3-day 

notification may be waived with the concurrence of the FSDO. The plan of activities 

must include at least the following:

a. Dates and times for all flights;

b. Name and phone number of the operator for the UAS aerial filming conducted 

under this grant of exemption;

c. Name and phone number of the person responsible for the on-scene operation of 

the UAS;

d. Make, model, and serial or N-Number of UAS to be used;

e. Name and certificate number of UAS PICs involved in the aerial filming;

f. A statement that the operator has obtained permission from property owners 

and/or local officials to conduct the filming production event; the list of those 

who gave permission must be made available to the inspector upon request;

g. Signature of exemption holder or representative; and

h. A description of the flight activity, including maps or diagrams of any area, city, 

town, county, and/or state over which filming will be conducted and the altitudes 

essential to accomplish the operation.

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

consenting to be involved and necessary for the filming production, as specified in the 

exemption holder’s MPTOM.

Unless otherwise specified in this grant of exemption, the UAS, the UAS PIC, and the UAS 

operations must comply with all applicable parts of 14 CFR including, but not limited to, 

parts 45, 47, 61, and 91.

This exemption terminates on April 30, 2017, unless sooner superseded or rescinded.

Sincerely,

/s/

John Barbagallo

Acting Deputy Director, Flight Standards Service
www.tradecraftuas.com

6 December 2014

U.S. Department of Transportation

Docket Management System

1200 New Jersey Ave., SE

Washington, DC 20590

RE: Exemption request under Section 333 of the FAA Modernization and Reform 

Act of 2012 and 14 C.F.R. Part 11

Dear Sir or Madam:

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

14 C.F.R. Part 11, TradeCraft LLC requests exemptions from several provisions of the 

Federal Aviation Regulations (FAR), specifically portions of 14 C.F.R Parts 45, 61, and

91 to allow among other things, commercial operations of its DJI Inspire 1 small 

Unmanned Aircraft System (sUAS) in the Continental United States (CONUS) by 

individuals who have FAA Commercial Rotorcraft Instrument certificates and have 

completed TradeCraft’s training program for commercial operation of sUAS.

The Inspire is an electric powered rotary wing sUAS that is capable of transmitting live 

airborne video images and location information to a Ground Control Station (GCS). The 

Inspire stores the photographs and data on board and makes them available for 

download after completion of the flight. The Inspire is 22 in x 22 in x 8 in and weighs 

6.4 pounds, well under the 55 lbs mandated in the FMRA. The Inspire can conduct 

hovering flight and has a maximum cruising speed of 42 knots. It is battery powered, 

has a flight endurance of 22 minutes and can operate in temperatures ranging from 0° 

to 40° C. The Inspire’s omni-directional antenna has a range of 2.1 km and operates in 

the 2.420 – 2.483 GHz frequency range.

DJI is a leader in the sUAS rotorcraft market. There are thousands of DJI products 

being used in the recreational and hobby industry. The Inspire can operate safely in the 

National Airspace System (NAS), without posing a threat to national security, by 

operating in accordance with the requirements discussed herein. Additionally, 

TradeCraft will utilize commercial rated pilots with extensive sUAS experience that will 

set them apart from most 333 applicants.

The Inspire’s capabilities, along with TradeCraft personnel’s prior experience 

conducting sUAS training, maintenance, and operations within the Department of 

Defense make it ideally suited to conduct commercial operations such as agriculture, 
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aerial surveying, and aerial photography within Visual Line of Sight (VLOS). Use of the 

Inspire reduces the need to operate manned aircraft, decreasing the risk to the pilot, 

crew, and those on the ground as the Inspire is carried to the area of operations and not 

flown there.

As a result of the Inspire’s size, weight, maximum speed, operational capability, and 

safety record the Inspire does not create a hazard to users of the NAS or the public. 

Neither does it pose a threat to national security. The petitioner states that, given the 

clear direction in Section 333, the strong equivalent level of safety surrounding the 

proposed operations, and the significant public benefit, including enhanced safety, 

reduction in environmental impacts, including reduced emissions associated with 

allowing UAS. Therefore, the FAA should grant TradeCraft the requested exemptions. 

Alternatively, if the FAA finds that modification of TradeCraft application is required for 

safe operation of the Inspire in the NAS, TradeCraft requests that the FAA delineate the 

required modifications and either process TradeCraft application as if the modifications 

were already made or allow TradeCraft to amend its application to incorporate the 

FAA’s findings.

The name and email address of the applicant are:

TradeCraft LLC

email: tradecraftuas@gmail.com
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Regulations from which the exemption is requested:

14 C.F.R Part 21

14 C.F.R. 45.23 (b)

14 C.F.R. 91.7 (a)

14 C.F.R. 91.9 (b) (2)

14 C.F.R. 91.103

14 C.F.R. 91.109

14 C.F.R. 91.119

14 C.F.R. 91.121

14 C.F.R. 91.151 (a)

14 C.F.R. 91.203 (a) & (b)

14 C.F.R. 91.405 (a)

14 C.F.R. 407 (a) (1)

14 C.F.R. 409 (a) (2)

14 C.F.R. 417 (a) & (b)

This exemption application is expressly submitted to fulfill Congress goal in passing 

Section 333 (a) through (c) of the Reform Act. This law directs the Secretary of 

Transportation to consider whether certain unmanned aircraft systems may operate 

safely in the NAS before completion of the rulemaking required under section 332 of the 

Reform Act. In making this determination, the Secretary is required to determine which 

types of UAS do not create a hazard to users of the NAS or the public or pose a threat 

to national security in light of the following:

• The UAS size, weight, speed, and operational capability;

• Operation of the UAS in close proximity to airports and populated areas; and 

• Operation of the UAS within visual line of sight of the operator.

Reform Act § 333 (a). Lastly, if the Secretary determines that such vehicles “may 

operate in the national airspace system, the Secretary shall establish requirements for 

the safe operation of such aircraft in the national airspace system.” Id. §333(c) 

(emphasis added)1

The FRMA expressly grants the FAA the authority to issue exemptions. This statutory 

authority by its terms includes exempting civil aircraft, as the term is defined under 

§40101 of the Act that includes sUAS, from the requirement that all civil aircraft must 

have a current airworthiness certificate.

The Administrator may grant an exemption from a requirement of a regulation 

prescribed under subsection (a) or (b) of this section or any sections 44702-44716 of 

this title if the Administrator finds the exemption in the public interest. 49 U.S.C. 

§44701(f) See also 49U.S.C. §44711(a); 49 U.S.C. 44704; 14 C.F.R. §91.203 (a) (1).

 1 Applicant interprets this provision to place the duty on the Administrator to not only process applications 

for exemptions under section 333, but for the Administrator to craft conditions for the operation of the 

UAS, if it should be determined that the conditions set fourth herein do not fulfill the statutory 

requirements for approval.
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TradeCraft LLC sUAS are rotorcraft, weighing 55 lbs. or less, including payload. They 

operate under normal conditions at a speed of no more than 50 knots and have the 

capability to hover and, move in the vertical and horizontal plane simultaneously. They 

will operate within line of sight and will only operate under strict risk mitigation 

guidelines as outlined in the TradeCraft LLC Commercial sUAS Flight Operations 

Procedures (hereinafter “the Manual”)2. Such operations will insure that the sUAS will 

“not create a hazard to users of the national airspace system or the public”3

Given the small size of the sUAS involved and the restricted environment within which 

they will operate, the applicant falls squarely within the zone of safety (an equivalent 

level of safety) in which Congress envisioned that the FAA must, by exemption, allow 

commercial operations of UAS to commence immediately. Also, due to the size of the 

UAS and the areas in which the relevant sUAS will operate, approval of the application 

presents no national security issue. Given the clear direction in Section 333 of the 

Reform Act, the authority contained in the Federal Aviation Act as amended; the strong 

equivalent level of safety surrounding the proposed operations, and the significant 

public benefit, including enhanced safety, reduction in environmental impacts, including 

reduced emissions associated with allowing sUAS for commercial operations, the grant 

requested exemptions is in the public interest. Accordingly, the applicant respectfully 

requests that FAA grant the requested exemption without delay.

Airworthiness

The Inspire is safe and fit for operation in the NAS under the conditions listed herein. In 

support of this application, TradeCraft LLC provides the following documents, the 

Inspire Flight and Maintenance Manual and the TradeCraft LLC Commercial sUAS 

Flight Operations Procedures.

 2 Applicant provides this manual as a Confidential document under 14 C.F.R. 11.35 (b) as the entire 

manual contains proprietary information that the applicant has not and will not share with others. The 

manual contains operating conditions and procedures that are not available to the public and are 

protected from release under the Freedom of Information Act 5 USC 552 et.seq.

3 Reform Act Section 333 (b)
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Mandatory Operating Conditions

TradeCraft LLC proposes that the grant of the exemption be subject to the following 

mandatory conditions which are based upon operating conditions set forth for operation 

of sUAS for commercial use pursuant to Certificates of Waiver or Authorization, with 

additional restrictions.

• Class III Flight Physical

• Aircraft will not exceed 42 knots

• Aircraft to remain within Visual Line of Sight (VLOS)

• Operations to occur during daylight hours

• Above Ground Level (AGL) altitude to be restricted to 400 feet

• Pilot in Command will file a NOTAM for each flight

Pilot Qualifications

Tradecraft proposes the following sUAS pilots:

Pilot in Command Qualifications Hours

Pilot 1

FAA Certificate: 3233322

FAA Commercial 

Instrument Rotary

Wing

Army sUAS master 

trainer graduate

Manned: 2683

Unmanned: 123

203 fixed wing launch/recovery

112 rotary wing launch/ recovery

Pilot 2

FAA Certificate: 3116078

FAA Commercial 

Instrument Rotary 

Wing

Manned: 363

Aircraft Information and Emergency Procedures

The Inspire is an inherently stable, lightweight aircraft that weighs 6.4 lbs. Moreover, 

although the aircraft can be configured to give the pilot full control of the aircraft and 

payload during flight, the Inspire has an advanced autopilot that flies the aircraft, 

managing altitude and flight path within the intended flight envelope at all times when 

the that flight mode is engaged. The autopilot limits maneuvering to simple airspeed, 

altitude, and turn rate changes. These limits are hard coded into the autopilot and 

define the aircraft’s normal flight operating envelope. The autopilot manages, pitch, roll, 

yaw and collective throttle to maintain target airspeed, target turn rate, and target 

altitude. All flight modes utilize GPS and in the event of unintended input the aircraft 

can be put into an operator controlled flight mode that allows for the aircraft to come to 

an immediate hover. Turn rates and airspeeds are limited by the autopilot and do not 

allow commands that are outside of the normal operating envelope.

Equally significant, the Inspire is comprised of composite materials, has energy 

absorbing landing gear that reduce damage in the event of a hard landing and is 

composed of carbon fiber and plastic components.
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The DJI inspire has additional safety features to facilitate safe integration into the NAS. 

The Inspire GCS software incorporates “Flight Restriction” areas around all B, C, and D 

airports. These flight restriction areas have different levels of notification, from warnings 

on the Ground Control Station, to altitude restrictions and finally not allowing the start of 

the motors. 

Another feature that is pilot defined, allows for altitude and distance limits to be set on 

the GCS. TradeCraft believes this is a key safety attribute that will allow seamless 

integration into the NAS and compliance with all FAA regulations.

The Inspire has three failsafe emergency procedures:

Loss of Communication: In the event the communication link with the operators ground 

control station is lost, the Inspire enters return to home mode after three seconds of 

transmission loss. The aircraft climbs to a Pilot defined altitude based on obstacle 

height. It then returns to the home waypoint, hovers for 15 seconds while trying to 

establish connection. The aircraft conducts a controlled landing then shuts off the 

motors if connection is not reestablished. 

Low Battery: The low battery emergency procedure is triggered when the DJI smart 

battery is depleted to a point that may affect the safe return of the aircraft; the Pilot in 

Command will Land as Soon as Possible. The thresholds for these warnings are 

automatically determined based on the current aircraft altitude and its distance from the 

Home point.

Loss of GPS: A loss of GPS while in guidance mode will cause the aircraft to hover 

using the onboard altimeter. This will allow the Pilot in Command to land the aircraft as 

soon as possible. Additionally, the aircraft utilizes an “optical flow” sensor that uses 

ultrasonic and image data to help the aircraft identify its position. This allows for the 

aircraft to hover when GPS is lost.
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Specific Exemption Requests and Equivalent Level of Safety Showings

14 C.F.R. § 45.23(b) – Display of marks; general

The regulation requires:

When marks include only the Roman capital letter "N" and the registration 

number is displayed on limited, restricted or light-sport category aircraft or 

experimental or provisionally certificated aircraft, the operator must also display 

on that aircraft near each entrance to the cabin, cockpit, or pilot station, in letters 

not less than 2 inches nor more than 6 inches high, the words "limited," 

"restricted," "light-sport," "experimental," or "provisional," as applicable.

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

needed as the UAS will have no entrance to the cabin, cockpit or pilot station on which 

the word “Restricted” can be placed as required by this provision. Two-inch lettering 

also is not possible given the overall size of the Inspire. TradeCraft LLC, therefore, 

requests an exemption to display, with one-inch lettering the word “Restricted” on the 

fuselage in compliance with §45.299(f).

The equivalent level of safety will be achieved by having the Inspire marked with one 

inch lettering on its fuselage because the pilot, observer, and others working with the 

sUAS will have the identification of the aircraft as “Restricted”. The FAA has issued 

similar exemptions to this regulation, including to Pioneer Hi-Bred International, Inc., 

Exemption No. 10810; Raytheon Missile Systems/Advanced Programs, Exemption 

Nos. 10167 and 8738; and Trimble Navigation Limited, Exemptions No. 10700 and 

11042.

14 C.F.R. § 91.7 (a) and (b): Civil aircraft airworthiness

Sections 91.7 (a) and (b) prohibit operation of a civil aircraft unless it is in airworthy 

condition. TradeCraft LLC requests an exemption from this regulation because the 

Inspire would not operate with an airworthiness certificate under the proposal set forth 

in this filing. Given the size of the aircraft and requirements contained in the Manual 

for maintenance and use of safety check lists prior to each flight, as set forth in in the 

operators manual, an equivalent level of safety will be provided.

14 C.F.R. § 91.109(a): Flight Instruction

Section 91.109 (a) provides that no person may operate a civil aircraft (except a 

manned free balloon) that is being used for flight instruction unless that aircraft has 

fully functioning dual controls.

The Inspire is a remotely piloted aircraft, and, by design, it does not have fully 

functional dual controls. Flight control is accomplished through the use of a control 

box that communicates with the aircraft via radio communications. Completing 

instruction through the TradeCraft training program will ensure an equivalent level of 

safety.

The FAA has approved exemptions for flight training without fully functional dual 

controls for a number of aircraft and for flight instruction in experimental aircraft. See 

Exemption Nos. 5778K and 9862A.
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14 C.F.R § 91.119 Minimum Safe Altitudes

Section 91.119 establishes safe altitudes for operation of civil aircraft. Specifically, 

Section 91.119 (c) limits aircraft flying over areas other than congested areas to an 

altitude of 500 feet above the surface, except over open water or sparsely populated 

areas. In those cases, the aircraft may not be operated closer than 500 feet to any 

person vessel, vehicle, or structure.

As set forth herein, the Inspire will never operate at higher than 400 feet AGL. 

Because agriculture, aerial survey work, and aerial imagery must be accomplished at 

relatively low altitudes, i.e. less than 500 feet AGL, an exemption from Section 

91.119(c) is needed.

The equivalent level of safety will be achieved given the size, weight speed, and 

material with which the Inspire is built. Also, no flight will be taken without the 

permission of the land owner or the party controlling the land. With advance notice to 

the landowner, all affected individuals will be aware of agriculture, survey, and aerial 

imagery. Compared to similar operations conducted with conventional aircraft or 

rotorcraft, which weigh thousands of pounds and carry flammable fuel, any risk 

associated with these operations will be far less than those currently allowed with 

such conventional aircraft operating at or below 500 feet AGL. 

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

Section 91.151 (b) prohibits an individual from beginning “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.

The Inspire’s battery provides 22 minutes of powered flight. Without an exemption 

from 14 C.F.R. §91.151, the Inspire’s flights would only be allowed to fly for 2 minutes. 

Given the limitations on its proposed operations and the location of those proposed 

operations, a lesser reserve for flight in VFR conditions is reasonable.

TradeCraft LLC believes that an exemption from 14 C.F.R. § 91.151 (a) is safe and 

consistent with the scope of a prior exemption. See Exemption 10673 (allowing 

Lockheed Martin Corporation to operate without compliance with 91.151 (a)). 

Operating the Inspire sUAS without 20 minutes of reserve fuel does not engender the 

type of risks that Section 91.151 (a) was meant to prevent. Given its weight and 

construction material, the risks are less then contemplated by the current regulation.

TradeCraft LLC believes that an equivalent level of safety can be achieved by 

maintaining 3 minutes of reserve fuel, which, allowing 19 minutes of flight time, would 

be more than adequate to return the UAS to its planned landing zone from anywhere 

in its visual line of site operating area.

Similar exemptions have been granted to others, including Exemptions 2689F, 5745, 

10673, and 10808.
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14 C.F.R § 91.405 (a); 91.407 (a) (1); 91.409 (a) (2); 91.417 (a): Maintenance 

inspections

Section 91.405 (a) requires that an aircraft operator or owner “[s]hall have that aircraft 

inspect as prescribed in subpart E of this part and shall between required inspections, 

excepts as provided in paragraph (c) of this section, have discrepancies repaired as 

prescribed in part 43 of this chapter.” Section 91.407 similarly makes reference to 

requirements in Part 43; Section 91.409 (a) (2) requires an annual inspection for 

issuance of an air worthiness certificate. Section 91.417 (a) requires that an owner or 

operator keep records showing certain maintenance work that has been accomplished 

by certificated mechanics, under Part 43, or licensed pilots and records of approval of 

the aircraft for return to service.

Maintenance of the Inspire 1 will be accomplished by TradeCraft LLC pilots pursuant 

to the manuals provided by DJI. An equivalent level of safety will be achieved 

because the Inspire is small in size, will operate only in predetermined areas, and is 

not a complex mechanical device. With the combined use of the DJI Inspire1 

operator’s and maintenance manual and TradeCraft LLC Commercial sUAS Flight 

Operations Procedures, the Pilot in Command of the Inspire will ensure that it is in 

safe working order prior to initiating flight, TradeCraft LLC pilots will perform required 

maintenance, and keep a log of any maintenance that is performed. Moreover, the 

Pilot in Command, prior to all flights will ensure the aircraft is safe for flight, which will 

provide an equivalent level of safety.
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Federal Register Summary

Pursuant to 14 C.F.R. § 11.81(f), the following summary is provided for publication 

in the Federal Register, should the FAA determine that publication is needed:

Docket No.: No. FAA-2014-

Petitioner: TradeCraft LLC

Section of 14 CFR: 14 C.F.R. § 45.23(b), 14 C.F.R. § 61.113(a) and (b), 

14 C.F.R. § 61.133(a), 14 C.F.R. § 91.7(a) and (b), 14 C.F.R. § 

91.109(a), 14 C.F.R. § 91.119, 14 C.F.R. § 91.151(a), 14 C.F.R. § 

91.405(a), 14 C.F.R.§ 91.407(a)(1), 14 C.F.R. § 91.409(a)(2), 14 C.F.R. 

§ 91.417(a).

Description of Relief Sought: TradeCraft LLC is seeking an exemption to 

conduct commercial agriculture, aerial survey, and imagery operations 

using a small Unmanned Aircraft System (55lbs or less) in areas of the 

continental United States.

Based upon the foregoing, TradeCraft LLC requests that the FAA grant it the necessary 

exemptions under Section 333 of the FAA Reform ACT and 49 U.S.C. §44701(f) of the 

Federal Aviation Act as requested herein to allow commercial operations of the Inspire

within the continental United States and its territories.

Sincerely,

TradeCraft LLC