Cody Porche 

Porche Aerial Imagery

5853 East Kayleigh Lane

Lake Charles, LA 70605 

(337) 540-8522 

codyporche@gmail.com

May 22nd, 2015 

U.S. Department of Transportation, Docket Operations 

West Building Ground Floor, Room W12-140 

1200 New Jersey Avenue, SE 

IN THE MATTER OF THE PETITION FOR EXEMPTION OF: 

Porche Aerial Imagery

FOR AN EXEMPTION SEEKING RELIEF FROM THE 

REQUIREMENTS OF TITLE 14 OF THE CODE OF FEDERAL 

REGULATIONS SECTIONS 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 

91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), AND 91.417(a) & (b) 

CONCERNING COMMERCIAL OPERATION OF DJI INSPIRE 1 

UNMANNED AIRCRAFT SYSTEMS 

PURSUANT TO SECTION 333 OF 

THE FAA MODERNIZATION AND REFORM ACT OF 2012 (PUBLIC 

LAW 112-95)

PORCHE AERIAL IMAGERY 1
Dear Sir or Madam: 

In accordance with Section 333 of the FAA Modernization and Reform act of 2012 (the Reform 

Act) and 14 CFR Part 11, Porche Aerial Imagery hereby applies for an exemption from the listed 

Federal Aviation Regulations (FARs) to allow commercial use of its Small Unmanned Aircraft 

Systems (SUAS), so long as such operations are conducted within and under the conditions 

outlined herein or as may be established by the FAA as required by Section 333. 

An exemption is being requested because (1) existing regulations will burden Porche Aerial 

Imagery (2) Porche Aerial Imagery can and will provide and maintain an utmost level of safety 

equal or greater to those provided by existing rules, and (3) the request is in the public interest. 

The FAA’s authority to issue exemptions from operating rules, and the Secretary’s authority 

granted by Section 333 of P.L. 112-95, Special Rules for Certain Unmanned Aircraft Systems, 

provide an opportunity to authorize certain SUAS operations in the National Airspace System 

(NAS) prior to implementation of the SUAS rule. This incremental step will allow Porche Aerial 

Imagery to legally and safely enter into the NAS. 

As described in detail below, the requested exemption would permit Porche Aerial Imagery to 

operate SUAS under controlled conditions in airspace that is (1) limited (2) predetermined (3) 

controlled as to access and (4) would provide safety enhancements to the already safe operations 

of those aircraft of similar size, weight, speed, and operating capability that have been granted 

entry into the NAS via the rules in Academy of Model Aeronautics (AMA) National Aircraft 

Safety Code. Approval of this exemption would thereby greatly enhance safety and fulfill the 

Secretary of Transportation’s (the Secretary) responsibilities to “...establish requirements for the 

safe operation of such aircraft systems in the national airspace system” per Section 333 (c) of the 

Reform Act. 

Porche Aerial Imagery is requesting exemption from the following regulations: 

14 CFR Part 21, Subpart H 

14 CFR 61.23 (a) 

14 CFR 61.113 (a) and (b) 

PORCHE AERIAL IMAGERY 2
14 CFR 91.109 

14 CFR 91.121 

14 CFR 91.151 (a) 

14 CFR 91.405 (a) 

14 CFR 91.407 (a)(1) 

14 CFR 91.409 (a)(1) 

14 CFR 91.409 (a)(2) 

14 CFR 91.417 (a) and (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 to consider whether certain 

unmanned aircraft systems may operate safely in the NAS before completion of the rule making 

required under Section 332 of the Reform Act. In making this determination, the Secretary is 

required to determine which types of UASs do not create a hazard to users of the NAS, to the 

public, or pose a threat to national security.

Section 333 of the Reform Act grants the Secretary authority to determine (1) if an unmanned 

aircraft system, as a result of its size, weight, speed, operating capability, proximity to airports and 

populated areas, and operation within visual line of sight (VLOS) does not create a hazard to 

users of the NAS or the public or pose a threat to national security, and (2) whether a certificate 

of waiver, certificate of authorization, or airworthiness certification under 49 USC 44704 is 

required for the operation of civil (non-governmental) UASs. Therefore, if the Secretary 

determines that such vehicles "may operate safely in the national airspace system, the Secretary 

shall establish requirements for the safe operation of such aircraft in the national airspace 

system".

LIMITED LIABILITY CORPORATION OVEVIEW 

Porche Aerial Imagery’s SUAS are quadcopters (or quadrotors, multirotors), weighing 6.5 or 

fewer lbs. (including payload). The SUAS possess simultaneous capability to hover and move in 

both the vertical and horizontal planes. They will operate only in visual line of sight (VLOS) and 

will operate only in tightly controlled and limited airspace. They are capable of operating at 

PORCHE AERIAL IMAGERY 3
speeds of up to 43 knots, but will be routinely operated at speeds no greater than 20 knots. They 

will routinely be operated below 200 feet above ground level (AGL), and never above 400 feet 

AGL. This AGL limitation is pertinent to the operation of normal business and is not only 

required to be monitored by the pilot in command but is also limited via the DJI Pilot App 

described in a future section of this document. 

Porche Aerial Imagery’s exemption request would permit its commercial operation of SUAS for 

aerial photography and videography in tightly controlled and limited airspace. Aerial 

photography and videography services will be offered to large or small corporations, small public 

events, private events, commercial and personal realtors, contractors, or property inspectors for 

use in, but not limited to, general aerial imagery requested by said “customers”. All operations 

will be conducted on private property and with the written and/or oral permission of the 

property owner(s). Operations will always be conducted in areas that are clear of people, except 

the pilot in command (PIC) and the PIC's helper(s). Such operations will ensure that the SUAS 

will "not create a hazard to users of the national airspace system or the public” .1

AIRCRAFT

Porche Aerial Imagery operates a DJI Inspire 1. The Inspire 1 is a SUAS manufactured by DJI, a 

well-known leader in quadcopter technology. DJI strives to bring new, innovative and safe 

technology to the aerial imagery industry and to assist companies worldwide in achieving said 

aerial imagery. They have an unparalleled commitment to research and development, an 

innovative culture, and a focus on transforming quadcopter technology into easy-to-use devices. 

The standard Inspire 1 quadcopter package includes the Inspire 1 itself, camera, gimbal, 

propulsion system, flight control system, 5.8 GHz remote controller, and 2.4 GHz 

communication system. The remote uses a 5.8 GHz frequency to prevent interference with the 

video/telemetry channel. This second channel allows for a constant connection with the Inspire 1 

to monitor it via a tablet (specifically, iPad Air 2) that is attached to the remote controller. 

Reform Act Section 333 (b) 1

PORCHE AERIAL IMAGERY 4
The Inspire 1 is approximately 17.2 inches x 17.7 in. x 11.9 in. in size. It has a maximum ascent 

speed of 16.4 feet per second, a maximum descent speed of 13.1 feet per second, and a 

maximum flight speed of 43 knots. While operating within VLOS, the remote control has a 

range of approximately 2,600 feet. The total weight (including the payload) is 6.4 lbs.

The Inspire 1 is equipped with a flight control system that provides incredible ease of use and 

stability. Pilots can control the Inspire l's movements in many directions including pitch (forward 

and backward), roll (left and right), elevator (up and down), and yaw (turn left and right). The 

flight control system can also provide intelligent orientation control (IOC), failsafe, battery level 

monitoring/battery warnings, and show the aircraft's current heading, direction, and exact 

distance from home on the onscreen radar. The built-in GPS system aids in stabilizing the 

aircraft and automatically and safely returns it back to its home point in any case where 

communication between the remote control and quadcopter are lost. 

The Inertial Measurement Unit (IMU) has a built-in inertial sensor and a barometric altimeter 

that measures both attitude (ATII) and altitude. The IMU incorporates both a 6-axis gyroscope 

and an accelerometer to monitor minuscule changes in tilt and movement. This allows the 

aircraft to compensate and adjust immediately, holding its position at all times.

The Inspire 1's compass reads geomagnetic information and assist the Global Positioning 

System (GPS) to accurately calculate the position and height of the aircraft. The Inspire 1 also 

has a built in Visual Positioning System (VPS) that allows takeoff and landing at the press of a 

button and keeps the Inspire 1 steady when GPS satellites cannot be required.

The Inspire 1 has LED flight indicators beneath each of its four rotor arms. The LEDs on the 

arms as well as one on the battery, illuminate to indicate the status of the flight control system 

and alert the PIC of any possible issues. Such highly advanced capabilities will ensure that the 

SUAS can be safely operated and "not create a hazard to users of the national airspace 

system or the public.”2

Reform Act Section 333 (b) 2

PORCHE AERIAL IMAGERY 5
SAFETY

In an effort to join the FAA in its mission to provide the safest, most efficient aerospace system in 

the world and to minimize the risk to the NAS or to persons and property on the ground, Porche 

Aerial Imagery agrees to be bound by the following limitations and conditions when conducting 

commercial operations under an FAA issued exemption: 

A. For the purposes of ensuring SUASs will be operated within the standards that 

the FAA has allowed in the AMA National Model Aircraft Safety Code: 

1. SUASs will not be flown:

1.1. In a careless or reckless manner. 

1.2. At a location where SUAS activities are prohibited. 

2. SUAS pilots will

2.1. Yield the right of way to all human-carrying aircraft. 

2.2. See and avoid all aircraft and a spotter must be used when appropriate. 

2.3. Not fly higher than 400 feet AGL or within three (3) miles of an airport 	 	 	

without notifying the airport operator. 

2.4.Not interfere with operations and traffic patterns at any airport, heliport or seaplane base 

except where there is a mixed use agreement. 

2.5. Not exceed a takeoff weight of 55 pounds (including payload). 

2.6. Ensure the aircraft is identified by affixing the owner's contact information to the outside 

of the SUAS. 

2.7. Not operate SUAS’s while under the influence of alcohol or while using any drug that 

could adversely affect the PIC's ability to safely control the model. 

2.8. Not operate SUAS's carrying pyrotechnic devices that explode or burn, or any device 

which propels a projectile or drops any object that creates a hazard to persons or property. 

3. SUASs will not be flown unless:

3.1. The aircraft, control system and pilot skills have successfully demonstrated all maneuvers 

intended or anticipated prior to the specific event. 

3.2. An inexperienced pilot is assisted by an experienced pilot. 

4. All pilots shall avoid flying directly over unprotected people, vessels, vehicles or structures and 

shall avoid endangerment of life and property of others. 

PORCHE AERIAL IMAGERY 6
5. A successful radio equipment ground-range check in accordance with manufacturer’s 

recommendations will be completed before the first flight of a new or repaired model aircraft. 

6. SUASs must use the radio-control frequencies currently allowed by the Federal 

Communications Commission (FCC). 

7. SUASs will not knowingly operate within three (3) miles of any pre-existing flying site without 

a frequency-management agreement.

8. Excluding takeoff and landing, no SUASs may be flown outdoors closer than 25 feet to any 

individual, except for PIC and the PIC's helper(s) located at the takeoff site. 

9. Under no circumstances may a pilot or other person touch a SUAS in flight while it is still 

under power, except to divert it from striking an individual. 

10. The PIC of the SUAS shall:

10.1. Maintain control during the entire flight, maintaining visual contact without 

enhancement other than by corrective lenses prescribed for the pilot. 

10.2. Fly using the assistance of a camera or First-Person (FPV) only in accordance with the 

procedures outlined in AMA Document #550. 

10.3. Fly using the assistance of autopilot or stabilization system only in accordance with the 

procedures outlined in AMA Document #560. 

11. The flying area must be clear of all utility wires or poles and an SUAV will not be flown 

closer than 50 feet to any above-ground electric utility lines. 

12. The flying area must be clear before the engine is started, except for PIC and the PIC 

helper(s). 

B. In addition to the above rules outlined by the AMA National Model Aircraft 

Safety Code and in an effort to enhance the safety offered by the already safe 

operations mentioned above, Porche Aerial Imagery also agrees to be bound by 

the following limitations and conditions:

1. Flights will be operated within VLOS of the PIC. 

2. Maximum total flight time for each operational flight will be 20 minutes. Flights will be 

terminated at 30% battery power reserve should that occur prior to the 25 minute limit. 

3. The SUAS will only operate in tightly controlled and limited airspace. 

PORCHE AERIAL IMAGERY 7
4. A pre-flight discussion will be conducted in regard to the planned SUAS operations prior to 

each flight. It will be mandatory that all personnel who will be performing duties within the 

boundaries of the safety perimeter be present for this meeting. 

5. The PIC and the PIC's helper(s) will have been trained in operation of SUAS and received 

up-to-date information on the particular SUAS to be operated. 

6. The pilot and the PIC's helper(s) will at all times be able to communicate by voice. 

7. If the SUAS loses communications or loses its GPS signal, the SUAS will have capability to 

return to a pre-determined location within the security perimeter and safely land based off of 

the initial home point determined prior to take off. 

8. The SUAS will have the capability to abort a flight in case of unpredicted obstacles or 

emergencies. 

9. All flights will be conducted no private property and with the written and/or oral permission 

of the property owner(s). 

10. Flights will always be conducted in areas that are clear of people, except for the PIC and the 

PIC's helper(s). 

11. Flights will not be conducted outdoors in visual meteorological conditions (VMC) and never 

during severe weather conditions. 

12. Flights will not occur in weather conditions that prevent the PIC from operating within visual 

line-of-sight (VLOS) at all times or in weather conditions that dramatically affect the UAS's 

flight (e.g. rain, high winds). 

13. If an operation occurs in an area where people could inadvertently enter the area, an 

operational border will be established with traffic cones. If it is not feasible to use traffic cones 

due to interference with the photography/videography, the PIC's helper(s) will be responsible 

for keeping a safe perimeter around the operation. The operation will cease immediately and 

be rescheduled if it's impossible to establish a safe perimeter around the operation.

14. The PIC will be responsible for logging all flights to ensure the comprehensive preventative 

maintenance plan can be followed, as described in the “Preventative Maintenance" section 

below.

15. The SUAS will not be routinely operated in the proximity of any airports. In any cases 

where SUAS must be operated within three (3) miles of an airport, the airport operator will 

be notified before the operation commences. 

PORCHE AERIAL IMAGERY 8
The operation of SUASs, weighing less than 7 lbs., conducted in the strict conditions as outlined 

above, will provide an equivalent level of safety supporting the grant of exemptions requested 

herein, including exempting the applicant from the requirements of Part 21 and allowing 

commercial operations.

These lightweight aircraft operate at slow speeds, close to the ground, and in a tightly controlled 

environment. As a result, they offer a much safer way to capture aerial photography and 

videography. Furthermore, the proposed operations represent a safety enhancement to the 

already safe operations that have been granted by the FAA for the establishment of the AMA 

National Model Aircraft Safety Code.

PRE-FLIGHT PLAN

The PIC will follow a comprehensive pre-flight checklist to ensure that the SUAS is in a 

condition for safe flight. This plan will be improved as needed in order to ensure all known safety 

precautions and/or safety precautions suggested by the manufacturer are being accounted for.

A. Pre-flight Inspection

1. Check that the remote control, Inspire 1 batteries, and tablet are all fully charged (Under 

no circumstances will flight be permitted if all devices do not have a minimum of 50% battery)

2. Inspect the Inspire 1 battery for signs of overuse or an overage of wear and tear 

including, but not limited to, swollen or bloated cells, dents, discoloration, etc). Clean the 

contact needles and pads if necessary

3. Gently rotate the motor shafts with your fingers and verify they do not exhibit excessive 

play or binding 

4. Verify that the propellers are mounted correctly. *Note that Porche Aerial Imagery’s 

SUAV is transported in a large case with all propellers installed. Therefore only a brief 

visual inspection is necessary at this step. 

5. Run finger along the edge of the propeller blade to check for any rough edges or 

imperfections. 

PORCHE AERIAL IMAGERY 9
6. Gently flex both sides of the propellers' blades to check for hairline cracks where the 

blades connect in the center of the propeller. 

7. Verify that the landing gear is secure (not cracked/broken/loose). 

8. Verify that the compass and compass cable is firmly attached to the landing gear. 

9. Verify that the Micro-SD card has been inserted and formatted. 

10. Verify that the damping absorbers are not broken and/or worn. 

11. Verify that the camera is secure and clean. Inspect the camera for signs of any wear and 

tear. 

12. Set the tablet in “Airplane Mode” mode to prevent distractions while flying. 

13. Set the tablet to forget any Wi-Fi networks in range in order to prevent the Wi-Fi 

connections from changing mid-flight. 

14. Verify that the tablet's audio is on to ensure the low battery warning and other alarms can 

be heard. 

B. Power up

1. Verify that the transmitter is in the “P” mode on F-A-P switch. 

2. Power on the equipment: 

2.1. SUAS battery (blinking green indicates GPS lock and ready to fly). 

2.2. Remote control (solid green and chime indicate lock on SUAS and ready to fly). 

3. Check the DJI Pilot app to ensure lock on 6+ satellites and home point is marked (for use 

by the failsafe feature). 

4. Calibrate the compass. 

5. Check MOD values. 

6. Place the Inspire 1 on open, flat ground with the battery indicators facing towards the 

PIC at least 10 feet away. 

C. DJI Pilot App 

1. Connect the tablet to the transmitter via USB. 

2. Launch the app. (select “Trust this device”) 

3. Verify the number of satellites is 6+. 

4. Verify signal strength. 

PORCHE AERIAL IMAGERY 10
5. Verify that the tablet battery has a full charge. 

6. Verify that both the PIC's and the Inspire 1's location is the same before taking off to 

ensure the home point has been accurately marked. 

7. Verify the location of the Inspire 1 in the "flight radar." If it is not in the correct position/

direction and/or shows a distance of "N/ A", it did not mark the home point. 

8. Use the "find my Inspire" feature to ensure the blue (home point location) and red (Inspire 

1 location) dots are in the same location on the screen. 

D. Ready to fly 

1. Verify that the remote antenna is perpendicular to the ground (pointing skyward). 

2. Verify that the front, flat face of the range extender is pointed toward the Inspire 1. 

3. Verify that the rear LED's are slowly blinking green and still connected to 6+ satellites. 

4. Start the Inspire 1 motors using the remote control. 

5. Verify the motors are functioning normally, and are not making any unusual noises, and 

are all spinning at the same speed. 

6. Verify that the area is clear of obstructions, people, power lines, etc. 

7. Take off and hover at approximately 6-8 feet above the takeoff point to verify that the 

Inspire 1has a solid GPS lock. If any abnormalities are noticed (drifting, flying in circles, 

etc) land immediately and repeat the "Pre-flight inspection" and "power up" sequences. 

8. Verify the Inspire 1 holds a steady position while yawing 360 degrees. 

9. Verify the Inspire 1 responds appropriately to all controls-yaw left/right, pitch forward/

backward, roll left/right, and throttle up/down. 

PREVENTATIVE MAINTENANCE

A comprehensive preventative maintenance plan will be followed in order to ensure the SUAS's 

software is up-to-date, the batteries are in good health, and the aircraft itself is always ready for 

safe flight. This maintenance plan includes a routine inspection after SUAV is retired for the day. 

Any abnormalities will be immediately addressed prior to any future flight.

PILOT IN COMMAND (PIC) QUALIFICATIONS

PORCHE AERIAL IMAGERY 11
The PIC does not hold an airman certificate or medical certification. Since the SUAS is similar 

in size, weight, speed, and operating capability as those currently allowed to be flown for hobby/

recreation, holding the PIC to those same set of standards will allow for an equivalent level of 

safety.

The PIC has years of computer systems and RC systems. Since the SUAS is controlled by a 

highly advanced computer system and runs on software that must be configured, updated, and 

maintained, computer proficiency is a must to ensure the SUAS is ready to be safely operated in 

the NAS. 

It cannot be assumed that a commercial pilot, approved to operate a helicopter or fixed wing 

aircraft, has the skill or ability to safely operate an unmanned aerial vehicle, operating at 400 feet 

AGL or lower, within strictly controlled pre-approved airspace. Since there are no standards for 

either private or commercial SUAS pilot certificates, knowledge of airspace regulations and 

dexterity in the control and operation of the SUAS acquired from actual operation of the aircraft 

will be the most important factors in establishing an equivalent level of safety. With that in mind, 

Porche Aerial Imagery proposes that its PIC be required to do the following prior to the first 

commercial operation: 

1. Perform a minimum of 20 flights without issue or log 20 hours of flight time (the greater of 

the two) with the Inspire 1.

2. Successfully learn and demonstrate all flight maneuvers in the Inspire 1 User Manual. 

(downloadable at http://www.dji.com/product/inspire-1/download).

3. Study and be familiar with all sections of "Inspire 1 User Manual”. 

PUBLIC INTEREST

Granting this exemption would benefit the public as a whole. SUASs offer a strong equivalent 

level of safety, a reduction in environmental impacts, and allow for a reduction in harmful 

emissions associated with the manned aircraft that are currently used for aerial photography and 

videography. Due to the size of the SUAS and the tightly controlled and limited airspace in 

which the SUAS will operate, approval of this application presents no risk to the public. 

Furthermore, the public and/or corporations will be able to legally acquire aerial photography 

PORCHE AERIAL IMAGERY 12
and videography to help in, but not limited to, monitor progress on major construction sites, 

review future construction sites for consideration, obtain videography of events, and even obtain 

aerial photographs of their new building. 

PRIVACY

Since the areas being photographed or filmed will be on private property, accessed only after 

given written and/or oral consent by the property owner(s), and clear of people, except for the 

PIC and the PIC's helper(s), approval of this application presents no risk to public privacy.

NATIONAL SECURITY

Due to the size of the SUAS and the tightly controlled and limited airspace in which the SUAS 

will operate, approval of this application presents no risk to national security.

REQUESTED EXEMPTIONS

Porche Aerial Imagery requests exemption from the following regulations since it's not possible to 

fully comply with them, and since attempting to follow them for the purposes of operating a 

SUAS would be a burden: 

Airworthiness Certificates 

14 CFR Part 21, Subpart H 

Subpart H establishes the procedural requirements for the issuance of airworthiness certificates 

as required by FAR 91.203(a)(1). Given the size and limited operating area associated with the 

aircraft to be utilized by Porche Aerial Imagery, an exemption from Part 21 Subpart H meets the 

requirements of an equivalent level of safety under Part 11 and Section 333 of the Reform Act. 

The Federal Aviation Act (49 USC 44701(f)) and Section 333 of the Reform Act both authorize 

the FAA to exempt aircraft from the requirement for an airworthiness certificate, upon 

consideration of the size, weight, speed, operational capability, and proximity to airports and 

populated areas of the particular SUAS. In all cases, an analysis of these criteria demonstrates 

that the SUAS operated without an airworthiness certificate, in the restricted environment and 

under the conditions proposed, will be at least safe, or safer, than a conventional aircraft 

operating with an airworthiness certificate without the restrictions and conditions proposed. 

PORCHE AERIAL IMAGERY 13
Medical certificates 

14 CFR 61.23(a) 

This regulation requires pilots of manned aircraft to hold a medical certificate. Since risks 

associated with the operation of the proposed SUAS are so diminished from the level of risk 

associated with any manned aircraft; the SUAS is of a size, weight, speed, and operational 

capabilities which make it much safer than any manned aircraft; since operations will occur in 

tightly controlled and limited airspace; and considering that all operations will be on private 

property that is clear of people, obtaining and maintaining a medical certificate would not 

improve the safety of the operation. In the very rare case of a mishap, the SUAS being flown will 

pose significantly less of a threat than manned helicopters and fixed wing aircraft because the 

SUASs are a fraction of the size and weight will be flown at a fraction of the speed, carry no 

flammable fuel, and carry no crew or passengers.

Private pilot privileges and limitations: Pilot in command 

14 CFR 61.113(a) and (b) 

These regulations limit private pilots to non-commercial operations. Because the SUAS will not 

carry a pilot or passengers; due to the SUASs size, weight, speed, and operational capabilities; 

and since operations will occur in tightly controlled and limited airspace, the proposed 

operations can achieve the equivalent level of safety of current operations that require a 

commercial pilot's license. Furthermore, since there are no standards for either private or 

commercial SUAS pilot certificates, knowledge of airspace regulations and dexterity in the 

control and operation of the SUAS acquired from actual operation of the aircraft will be the 

most important factors in establishing an equivalent level of safety. It cannot be assumed that a 

commercial pilot, approved to operate a manned helicopter or fixed wing aircraft, has the skill 

or ability to safely operate an unmanned aerial vehicle, operating at 400 feet AGL or lower, 

within strictly controlled pre-approved airspace.

Flight Instruction 

14 CFR 91.109 

This regulation provides that no person may operate a civil aircraft (except a manned free 

PORCHE AERIAL IMAGERY 14
balloon) that is being used for flight instruction unless that aircraft has fully functioning dual 

controls. 

SUASs and remotely piloted aircraft, by their design do not have fully functional dual controls. 

Flight control is accomplished through the use of a control box that communicates with the 

aircraft via radio communications. The FAA has approved exemptions for flight training without 

fully functional dual controls for a number of aircraft and for flight instruction in experimental 

aircraft. The equivalent level of safety provided by the fact that neither a pilot or passengers 

will be carried in the aircraft and by the size and speed of the aircraft. 

Altimeter Settings 

14 CFR 91.121 

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

reference to an altimeter that is set " ... to the elevation of the departure airport or an 

appropriate altimeter setting available before departure." As the SUAS may not have a 

barometric altimeter, but instead a GPS altitude read out, an exemption may be needed. An 

equivalent level of safety will be achieved by the operator by confirming the altitude of the 

launch site shown on the GPS altitude indicator before flight.

Fuel Requirements for Flight in VFR Conditions 

14 CFR 91.151(a) 

This regulation prohibits an individual from beginning "a flight in an airplane under VFR 

conditions unless (considering wind and forecast weather conditions) there is enough fuel to fly 

to the first point of intended landing, and, assuming normal cruising speed - (1) During the day, 

to fly after that for at least 30 minutes; or (2) At night, to fly after that for at least 45 minutes.” 

The battery powering the SUAS provides approximately 20 minutes of powered flight. That 

would make it impossible to meet the 30 minute reserve requirement. Given the limitations on 

the SUAS's proposed flight area and the location of its proposed operations within a 

predetermined area, a longer time frame for flight in daylight or night VFR conditions is 

reasonable. An equivalent level of safety can be achieved by limiting flights to 20 minutes or 30% 

of battery power (whichever occurs first). This restriction would be more than adequate to return 

the SUAS to its planned landing zone from anywhere in its limited operating area.

PORCHE AERIAL IMAGERY 15
Maintenance Inspections 

14 CFR 91.405(a); 14 CFR 91.407(a)(1); 14 CFR 91.409(a)(1); 14 CFR 91.409(a)(2); 14 CFR 

91.417(a) and (b) 

These regulations require that an aircraft operator or owner "shall have that aircraft inspected 

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

provided in paragraph (c) of this section, have discrepancies repaired as prescribed in part 43 of 

this chapter ... ," and others shall inspect or maintain the aircraft in compliance with Part 43. 

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

these sections will not apply. Maintenance will be accomplished by the operator pursuant to 

the aforementioned Inspire 1 user manual. An equivalent level of safety will be achieved 

because these small SUASs are very limited in size, will carry a small payload, and operate only 

in restricted areas for limited periods of time. If mechanical issues arise, the SUAS can land 

immediately and will be operating from no higher than 400 feet AGL. As outlined in the 

aforementioned Pre-flight Action Plan, the operator will ensure that the SUAS is in working 

order prior to initiating flight and perform maintenance as required. Moreover, the operator is 

the person most familiar with the aircraft and best suited to maintain the aircraft in an airworthy 

condition to provide the equivalent level of safety.

SUMMARY

In accordance with 14 CFR Part 11, the following summary is provided for publication in the 

Federal Register:

The applicant seeks an exemption from the following rules: 14 CFR Part 21, Subpart 

H; 14 CFR 61.113(a) and (b); 14 CFR 91.109; 14 CFR 91.121; 14 CFR 91.151; (a); 14 CFR 

91.405(a); 14 CFR 91.407(a)(1); 14 CFR 91.409(a)(1); 14 CFR 91.409(a)(2); 14 CFR 91.417(a) 

and (b) to commercially operate small unmanned aircraft systems (55 lbs. or less) in 

order to safely and legally capture aerial photography and videography for use by 

large or small corporations, small public events, private events, commercial and 

personal realtors, contractors, or property inspectors.

PORCHE AERIAL IMAGERY 16
The operation of SUAS conducted in the strict conditions outlined above, will provide an 

equivalent and/or greater level of safety supporting the grant of the exemptions requested 

herein, including exempting the applicant from the requirements of Part 21 and allowing 

commercial operations. These lightweight aircraft operate at slow speeds, close to the ground, 

and in a sterile environment, and as a result, are far safer than existing operations conducted with 

helicopters operating in close proximity to the ground, people, or other buildings in the vicinity.

Given the small size of the SUASs involved, the slow speed at which they must be operated in 

order to capture photos and videos, and the restricted environment within which they will 

operate, the Inspire 1 demonstrates that it can be operated within an equivalent level of safety in 

which Congress envisioned that the FAA must, by exemption, allow commercial operations of 

SUASs to commence immediately.

Also, due to the size of the SUASs and the restricted areas in which the relevant SUASs will 

operate, approval of this application presents no threat to national security. Given the clear 

direction in Section 333 of the Reform Act, the authority contained in the Federal Aviation Act, 

the strong equivalent level of safety surrounding the proposed operations, the significant public 

benefit - including enhanced safety, reduction in environmental impacts, no emissions, ability to 

legally obtain aerial photography and videography services - the grant of the requested 

exemptions is in the public interest. Accordingly, Porche Aerial Imagery respectfully requests that 

the FAA grant the requested exemption without delay.

Satisfaction of the criteria provided in Section 333 of the Reform Act - size, weight, speed, 

operating capability, proximity to airports and populated areas, operation within the visual line 

of sight, public safety, and national security- provide more than adequate justification to grant 

Porche Aerial Imagery the requested exemption, allowing for commercial operations as described 

herewith.

With anticipation,

Cody Porche

Owner, Porche Aerial Imagery

PORCHE AERIAL IMAGERY 17