1 | Reeder Flying Service, Inc. Petition for Exemption under Section 333

UNITED STATES OF AMERICA DEPARTMENT OF TRANSPORTATION FEDERAL AVIATION

ADMINISTRATION WASHINGTON, DC

Regulatory Docket No.

______________________________

IN THE MATTER OF THE PETITION FOR EXEMPTION OF:

REEDER FLYING SERVICE INC.FOR AN EXEMPTION SEEKING RELIEF FROM THE REQUIREMENTS OF

TITLE 14 OF THE CODE OF FEDERAL REGULATIONS SECTIONS

14 CFR Part 21 subpart H

14 CFR 45.23 (b)

14 CFR 61.101 (e) (4) and (5)

14 CFR 61.113 (a) & (b)

14 CFR 91.7 (a)

14 CFR 91.9 (b) (2)

14 CFR 91.103 (b)

14 CFR 91.109

14 CFR 91.119 (b) & (c)

14 CFR 91.121

14 CFR 91.151

14 CFR 91.203 (a) & (b)

14 CFR 91.405 (a)

14 CFR 91.407 (a) (1)

14 CFR 91.409 (a)(1) & (2)

14 CFR 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)
2 | Reeder Flying Service, Inc. Petition for Exemption under Section 333

UAS Integration Office – Special Rules Coordinator

Federal Aviation Administration

U. S. Department of Transportation

Docket Management System

1200 New Jersey Ave., SE Washington, DC 20590

November 13, 2015

Re: Petition for Exemption for Use of UAS for Real Estate, Public Interest, Small Business

Applications under Section 333, Title 14

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

and 14 CFR Part 11, Reeder Flying Service Inc., operator of an Unmanned Aircraft System

(UAS), hereby applies for an exemption from the listed Federal Aviation Regulations

(“FARs”) to allow commercial operation of its UAS, 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.

Commercial operation of an UAS, as described herein, which are equipped with camera(s) and

sensors, would operate in the following manner:

1. Aerial photography and/or video for public and/or private use including real estate,

architecture, land surveying, engineering and other related professional activities.

2. Aerial video and/or photography for public and/or private use including television, public

events, cinematography and news gathering.

3. Aerial inspection/photography of residential/commercial structures under contract with

the owners or local government authority.

4. Aerial inspection/photography/data collection of residential/commercial utility

infrastructure including but not limited to electrical power lines, structures and related facilities, wind

turbines and cell towers, gas pipeline right of ways, installations and facilities.

5. Aerial video/photography or providing live video feed to assist with search and rescue

operations in cases of an emergency or natural disaster only when the local authorities or

government has requested it by contract or donation.

6. The ability to offer training to persons individually or belonging to both private and/or

public organizations that have interests in the use and application of a UAS for the purpose of

the safe operation of a UAS to enhance the safety of the National Airspace System (NAS) as well

as for the protection of the persons and property.

As described fully below, the requested exemption would permit the operation of a UAS under 

controlled conditions in the NAS that would be a) limited b) controlled c) predetermined and d) 

will provide safety enhancements to the already safe operations in the industry presently using

conventional aircraft. Approval of this exemption would thereby enhance safety and fulfill

the Secretary of Transportation’s (the FAA Administrator’s) responsibilities to “....establish

requirements for the safe operation of such aircraft systems in the national airspace 

system.”
3 | Reeder Flying Service, Inc. Petition for Exemption under Section 333

BACKGROUND

Located in Twin Falls Idaho Reeder Flying Service was founded in 1941 by Charles T. 

Reeder. His aviation innovations led the way in many areas and has left a lasting 

impression on the aviation community.

Over the past 75 years the company has evolved from a family run agricultural support

operation to a full service FBO and helicopter charter company. Reeder Flying Service 

has grown and changed with the times in aviation.

Since 1960, Reeder Flying Service has provided helicopter services. The Company 

operates under FAA 135, 133, 137 certificates.

In 2012 Reeder Flying Service was purchased by three local businessmen, Jack M. 

Hunsaker, David R. Price and Alan Anderson.

The integration of UASs into the National Airspace System (NAS) has the promise and

potential to be transformative in the ways in which the public, educational and research

institutions, businesses and non-profits pursues their interests and goals. Reeder Flying 

Service, Inc., as a long standing member of the commercial aviation community, feels it is 

in an excellent position to participate in this expanding market. Using its understanding 

and expertise in commercial aviation, Reeder feels it has an important role to play in

furthering the safe, lawful use and professional development of commercial unmanned 

aerial systems.

Reeder Flying Service Inc. will conduct its business using the DJI Inspire 1 UAS. The

Inspire 1 is a vertical takeoff and landing UAS with a maximum gross weight of less than

55 pounds and a maximum speed of less than 50 mph. The Inspire 1 is driven by electric

motors and powered by lithium polymer batteries.

The aircraft registration application and all required supporting documentation for this UAS 

has been forwarded to the FAA Aircraft Registration Branch, AFS-750, P.O. Box 25504, 

Oklahoma City, OK 73125-0504. The registration has been returned with the UAS 

registered as N644RD.

BASIS FOR PETITION

Petitioner, Reeder Flying Service Inc., pursuant to the provisions of the Federal Aviation 

Regulations (14 C.F.R. § 11.61) and the FAA Modernization and Reform Act of 2012 

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

petitions the Administrator to commercially operate the DJI Inspire 1 UAS in the National 

Airspace System (NAS), and for an exemption from the requirements of 14 CFR 21 

subpart H; 14 CFR 45.23(b); 14 CFR 61.101(e) (4) & (5); 14 CFR 61.113(a) and (b); 14 

CFR 91.7(a); 14 CFR 91.9(b)(2); 14 CFR 91.103 (b); 14 CFR 91.109; 14 CFR 91.119(c); 

14 CFR 91.121; 14 CFR 91.151; 14 CFR 91.203(a) and (b); 14 CFR 91.405(a); 14 CFR

91.407(a)(1); 14 CFR 91.409 (a)(1) and (2); 14 CFR 91.417(a) and (b). 
4 | Reeder Flying Service, Inc. Petition for Exemption under Section 333

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

unmanned aircraft and its operation, Reeder Flying Service Inc.’s operation of DJI Inspire 

1 UAS meets the conditions of FMRA Section 333 and therefore, will not require an 

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

Accordingly, Reeder Flying Service Inc. requests relief from Sections 91.405(a), 

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

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

Reeder Flying Service Inc. submits that the requested relief is proper since an equivalent 

level of safety will be ensured. Reeder Flying Service Inc. will use experienced personnel 

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

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

the Reeder Flying Service Inc. UAS Flight Operations Manual, UAS Maintenance Log, and 

DJI Inspire 1 User Manual.) Furthermore, Reeder Flying Service Inc. will document

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

Reeder Flying Service Inc. seeks relief from Section 91.7(a)- Civil aircraft airworthiness, 

because the DJI Inspire 1 UAS do not require an airworthiness certificate in accordance 

with 14 C.F.R. Part 21, Subpart H. As such, Reeder Flying Service Inc. submits that it will 

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

determining that the UAS are in compliance with the operating documents (i.e., the Reeder 

Flying Service Inc. UAS Flight Operations Manual, UAS Maintenance Log, and DJI Inspire 

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

In accordance with 14 C.F.R. § 11.81, Reeder Flying Service Inc. provides the following 

information in support of its petition for exemption:

I. Name And Address Of The Petitioner.

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

Reeder Flying Service Inc.

644 Airport Loop

Twin Falls ID. 83301

Tel: (208) 733-5920

website: www.reederflying.com

II. The Specific Sections Of 14 CFR From Which Reeder Flying Service Inc. Seeks 

Exemptions

14 CFR 21 subpart H; 14 CFR 45.23(b); 14 CFR 61.101(e)(4) and (5), 14 CFR 61.113(a) 

and (b); 14 CFR 91.7(a); 14 CFR 91.9(b)(2); 14 CFR 91.103; 14 CFR 91.109; 14 CFR 

91.119(b) and (c); 14 CFR 91.121; 14 CFR 91.151; 14 CFR 91.203 (a) and (b); 14 CFR 

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

III. The Extent Of Relief Reeder Flying Service Inc. Seeks And The Reason Reeder 

Flying Service Inc. Seeks The Relief.
5 | Reeder Flying Service, Inc. Petition for Exemption under Section 333

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

Act”) and 14 CFR Part 11, Reeder Flying Service Inc., operator of an Unmanned Aircraft 

System (UAS), hereby applies for an exemption from the listed Federal Aviation 

Regulations (“FARs”) to allow commercial operation of its UAS, 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.

Commercial operation of an UAS, as described herein, which are equipped with camera(s) 

and sensors, would operate in the following manner:

1. Aerial photography and/or video for public and/or private use including real estate,

architecture, land surveying, engineering and other related professional activities.

2. Aerial video and/or photography for public and/or private use including television, public

events, cinematography and news gathering.

3. Aerial inspection/photography of residential/commercial structures under contract with

the owners or local government authority.

4. Aerial inspection/photography/data collection of residential/commercial utility

infrastructure including but not limited to electrical power lines, structures and related facilities, wind

turbines and cell towers, gas pipeline right of ways, installations and facilities.

5. Aerial video/photography or providing live video feed to assist with search and rescue

operations in cases of an emergency or natural disaster only when the local authorities or

government has requested it by contract or donation.

6. The ability to offer training to persons individually or belonging to both private and/or

public organizations that have interests in the use and application of a UAS for the purpose of

the safe operation of a UAS to enhance the safety of the National Airspace System (NAS) as well

as for the protection of the persons and property.

As described fully below, the requested exemption would permit the operation of a UAS 

under controlled conditions in the NAS that would be a) limited b) controlled c) 

predetermined and d) will provide safety enhancements to the already safe operations in 

the industry presently using conventional aircraft. Approval of this exemption would 

thereby enhance safety and fulfill the Secretary of Transportation’s (the FAA 

Administrator’s) responsibilities to “....establish requirements for the safe operation of such 

aircraft systems in the national airspace system.”

14 C.F.R. Part 21, Subpart H: Airworthiness Certificates Subpart H- Airworthiness 

Certificates
6 | Reeder Flying Service, Inc. Petition for Exemption under Section 333

The regulation 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 the Applicant, 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 U.S.C.§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 UAS. 

In all cases, an analysis of these criteria demonstrates that the UAS operated without an 

airworthiness certificate, in the restricted environment and under the conditions proposed 

will be at least as safe, or safer, than a conventional aircraft (fixed wing or rotorcraft) 

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

The UAS to be operated hereunder is less than 55 lbs. fully loaded, carries neither a pilot 

nor passenger, carries no explosive materials or flammable liquid fuels, and operates 

exclusively within a secured and designated area. Unlike other civil aircraft, operations 

under this exemption will be tightly controlled and monitored by both the operator and 

under the requirements and in compliance with local public safety requirements. These

safety enhancements provide a greater degree of safety to the public and property owners 

than conventional operations conducted with airworthiness certificates issued under 14 

C.F.R. Part 21, Subpart H.

Lastly, application of these same criteria demonstrates that there is no credible threat to 

national security posed by the UAS, due to its size, speed of operation, location of 

operation, lack of explosive materials or flammable liquid fuels, and inability to carry a 

substantial external load.

14 C.F.R. § 45.23 (b) - Marking of the Aircraft

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 

“Experimental” can be placed. Given the size of the UAS, two-inch lettering will be 

impossible. The word “Experimental” will be placed on the fuselage in compliance with 

§45.29 (f). The equivalent level of safety will be provided by having the UAS marked on its 

fuselage as required by §45.29 (f) where the pilot, observer and others working with the 

UAS will see the identification of the UAS as “Experimental.”

14 CFR § 61.101 (e) (4) and (5): Recreational Pilot Privileges and Limitations: Pilot in 

Command.
7 | Reeder Flying Service, Inc. Petition for Exemption under Section 333

Relief is requested to the extent necessary to allow a PIC holding a recreational pilot level 

certificate and who has met certain flight-hour and currency requirements, to conduct the 

proposed UAS flight operations for compensation or hire and in furtherance of a business.

The issuance of a Recreational Pilot Certificate requires the applicant to be trained in and 

pass a knowledge test on the aeronautical knowledge areas listed in 14 CFR § 61.97 (b), 

and demonstrate to an examiner flight proficiency as outlined in 14 CFR § 61.98. 

Reeder Flying Service, Inc. submits that to the extent that a commercial UAS, operating 

under the grant of exemption, will impact the airspace system, a recreational pilot 

certificate will provide an adequate and equivalent level of expertise to ensure safety to the 

public. 

14 C.F.R. § 61.113 (a) and (b): Private Pilot Privileges and Limitations: Pilot in 

Command.

Relief is requested to the extent necessary to allow a PIC holding a private pilot 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.

The issuance of a Private Pilot Certificate requires the applicant to be trained in and pass 

a knowledge test on the aeronautical knowledge areas listed in 14 CFR § 61.105 (b), and 

demonstrate to an examiner flight proficiency as outlined in 14 CFR § 61.106. 

Reeder Flying Service, Inc. submits that to the extent that a commercial UAS, operating 

under the grant of exemption, will impact the airspace system, a private pilot certificate will 

provide an adequate and equivalent level of expertise to ensure safety to the public. 

As set forth more fully below, Reeder Flying Service Inc. submits that an equivalent level 

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

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

demonstrating that the PIC is able to safely operate either the DJI Inspire 1 UAS in a 

manner consistent with the operations specifications as described in this exemption, 

including evasive and emergency maneuvers, as well as maintaining appropriate 

distances from people, vessels, vehicles and structures.

14 C.F.R. §91.7(a): Civil Aircraft Airworthiness

Relief from Section 91.7(a). Relief from Section 91.7(a) entitled Civil aircraft airworthiness, 

is requested to the extent required to allow Reeder Flying Service Inc. to determine that 

the DJI Inspire 1 UAS are in airworthy condition prior to every flight by ensuring that the 

UAS is in compliance with the operating documents (i.e., the Reeder Flying Service Inc.

UAS General Operations Manual, UAS Daily Flight Log preflight airworthiness sign off, 

UAS 50 hour/ 200 flight Inspection and DJI Inspire 1 Instruction Manual).

Reeder Flying Service Inc. seeks the requested relief because the DJI Inspire 1 UAS does 

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

Therefore, Reeder Flying Service Inc. will ensure that the DJI Inspire 1 UAS are in 
8 | Reeder Flying Service, Inc. Petition for Exemption under Section 333

airworthy condition based upon its compliance with the operating documents noted above

prior to every flight, and further, determine that the aircraft is in condition for safe flight, as 

stated in the conditions and limitations below.

14 C.F.R. § 91.9 (b) (2): Civil Aircraft Flight Manual in the Aircraft

Section 91.9 (b) (2) provides: No person may operate a U.S.-registered civil aircraft ... (2) 

For which an Airplane or Rotorcraft Flight Manual is not required by §21.5 of this chapter, 

unless there is available in the aircraft a current approved airplane or Rotorcraft Flight 

Manual, approved manual material, markings, and placards, or any combination thereof. 

The UAS, given its size and configuration has no ability or place to carry such a flight 

manual on the aircraft, not only because there is no pilot on board, but because there is no 

room or capacity to carry such an item on the aircraft. The equivalent level of safety will be 

maintained by keeping the manufacturer provided user manual at the ground control point 

where the pilot flying the UAS will have immediate access to it.

14 C.F.R. § 91.103(b): Preflight Action

This regulation requires each pilot in command to take certain actions before flight to 

insure the safety of flight, regarding runway lengths and use of approved flight manuals. 

As FAA approved rotorcraft flight manuals will not be provided for the aircraft an exemption 

will be needed. 

The PIC will take all actions as stated in the manufacturer’s user manual and the Reeder 

Flying Service, Inc. UAS General Operations Manual, including but not limited to reviewing 

weather, flight battery requirements, landing and takeoff distances and aircraft 

performance data before initiation of flight.

14 C.F.R. §91.109: Flight Instruction

Section 91.103 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. 

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

Flight control is accomplished through the use of a ground control station 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 is provided 

by the fact that neither a pilot nor passengers will be carried in the aircraft and by the size 

and speed of the aircraft.

14 C.F.R. §91.119 (b) and (c): Minimum Safe Altitudes

Section 91.119 establishes safe altitudes for operation of civil aircraft. Section 91.119 (d) 

allows helicopters to be operated at less than the minimums prescribed, provided the 

person operating the helicopter complies with any route or altitudes prescribed for 

helicopters by the FAA. 

As this exemption is for a UAS that is a rotorcraft and the exemption requests authority to 

operate at altitudes up to 400 AGL, or not more than 200 above an elevated platform from 

which aerial data collection is planned, an exemption may be needed to allow such 

operations. As set forth herein, the UAS will never operate at higher than 400 AGL with the 
9 | Reeder Flying Service, Inc. Petition for Exemption under Section 333

exception that in circumstances where the UAS is used to survey or photograph a 

structure whose height exceeds 400 feet AGL, the UAS will not be operated more than 

200 feet above the highest point on the structure. It will however be operated in a defined

area with security perimeter, where buildings and people will not be exposed to operations 

without their pre-obtained consent.

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

well as the location where it is operated. No flight will be taken without the permission of 

the property owner or local officials. Because of the advance notice to the property owner 

and participants in the filming activity, all affected individuals will be aware of the planned 

flight operations. Compared to flight operations with aircraft or rotorcraft weighting far more 

than the maximum 55 lbs. proposed herein and the lack of flammable fuel, any risk 

associated with these operations is far less than those presently presented with 

conventional aircraft operating at or below 500 AGL. In addition, the low-altitude 

operations of the UAS will ensure separation between these UAS operations and the 

operations of conventional aircraft that must comply with Section 91.119.

14 C.F.R. §91.121 Altimeter Settings

Relief from Section 91.121, entitled Altimeter settings, is required to allow flight operations 

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

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

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), Reeder Flying Service Inc. seeks the requested relief because 

the DJI Inspire 1 UAS’s altimeter may be set on the ground to zero feet AGL, rather than 

the local barometric pressure or field altitude, before each flight. 

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

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

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

since the DJI Inspire 1 UAS are equipped with a barometric pressure sensor and GPS 

equipment, which automatically ensures that a ground level pressure setting will be 

established prior to each flight, and provides the PIC with altitude information of the UA on

the heads-up display of the GCS.

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

Relief from Section 91.151 entitled Fuel requirements for flight in VFR conditions, is 

requested to the extent required to allow flights of the battery powered DJI Inspire 1 UAS 

during daylight hours in visual meteorological conditions (VMC), under visual flight rules 

(VFR), for a total duration of 20 minutes to the first point of intended landing and, 

assuming normal cruising speed, to fly after that for at least 5 minutes. 

Reeder Flying Service Inc. seeks the requested relief because without an exemption from 

Section 91.151, the flight time duration of the battery powered DJI inspire 1 UAS will 

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

Reeder Flying Service Inc. proposes to conduct pursuant to this Petition.
10 | Reeder Flying Service, Inc. Petition for Exemption under Section 333

Significantly, as set forth below, the technical specifications of the DJI Inspire 1 UAS, the 

DJI Inspire 1 operating documents, and Reeder Flying Service Inc. proposed operating 

limitations, ensure that Reeder Flying Service Inc. will safely operate the battery powered

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

visual flight rules (VFR), with enough battery power to fly for a total duration of 20 minutes 

to the first point of intended landing and, assuming normal cruising speed, to fly after that 

for at least 5 minutes. Applicant believes that an equivalent level of safety can be achieved 

by limiting flights to 25 minutes or 25% of battery power— whichever happens first. This 

restriction would be more than adequate to return the UAS to its planned landing zone 

from anywhere in its limited operating area.

14 C.F.R. §91.203 (a) and (b): Carrying Civil Aircraft Certification and Registration

The regulation provides in pertinent part:

(a) Except as provided in § 91.715, no person may operate a civil aircraft unless it has 

within it the following: (1) An appropriate and current airworthiness certificate. . . .

(b) No person may operate a civil aircraft unless the airworthiness certificate required by 

paragraph (a) of this section or a special flight authorization issued under §91.715 is 

displayed at the cabin or cockpit entrance so that it is legible to passengers or crew.

The UAS fully loaded weighs no more than 55 lbs. and is operated without an onboard 

pilot. As such, there is no ability or place to carry certification and registration documents 

or to display them on the UAS. An equivalent level of safety will be achieved by keeping 

these documents at the ground control point where the pilot flying the UAS will have 

immediate access to them, to the extent they are applicable to the UAS.

14 C.F.R. §91.405 (a); 407 (a) (1); 409 (a) (2); 417(a) & (b): Maintenance Inspections

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 I 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 to the applicant. Maintenance will be accomplished 

by the operator pursuant to the manufacturer’s User manual and Company Operations 

Manual. An equivalent level of safety will be achieved because the UAS is very limited in 

size and will carry a small payload and operate only in restricted areas for a limited period 

of time. If mechanical issues arise the UAS can land immediately and will be operating 

from no higher than 400 feet AGL. The operator will ensure that the UAS is in working 

order prior to initiating flight, perform required maintenance, and keep a log of any 

maintenance performed. 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. An equivalent level of safety will be achieved because 

maintenance and inspections will be performed in accordance with the UAS 

Manufacturer’s User Manual. As provided in the Operations Manual, the operator will 

ensure that the UAS is in working order prior to initiating flight and perform required 

maintenance needed.
11 | Reeder Flying Service, Inc. Petition for Exemption under Section 333

IV. The Reasons Why Granting Reeder Flying Service Inc.’s Request Would Be In 

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

PUBLIC INTEREST AND HOW THE PUBLIC WILL BENEFIT

This exemption request will permit Reeder Flying Service Inc. to operate its UAS 

commercially for the purpose of aerial filming, photography and data collection to include: 

commercial and residential real estate, infrastructure inspections, construction, 

architecture, scientific research, environmental assessment, land surveying and mapping 

and other applicable areas. Reeder Flying Service Inc. will provide a service that is 

beneficial to industries and organizations that are already using, and seeking to use, UASs 

for these purposes with a legal and safe option. This will benefit the public with the 

controlled operation of UASs and increase integration into the NAS.

Granting the present petition will further the public interest by allowing Reeder Flying 

Service Inc. to perform safely, efficiently, and economically, aerial video and photography 

of construction sites, real estate, and landscape over certain areas of the United States.

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

and provide significant benefits to the economy.

The integration of UASs into the NAS will not only replace traditionally more expensive 

options or approaches, it will enable work to be done and decisions to be made in ways

that were simply impossible to do previously. The commercial deployment of small

unmanned aircraft systems offers the public a new, highly efficient and relatively

inexpensive platform for collecting, analyzing and utilizing data and photographic/video

imagery.

In deploying its UAS, Reeder Flying Service Inc. has developed specific performance

standards, operating requirements, protocols and work processes that are aligned with the

FAA’s continuing mission, and will result in safe operating practices that are consistently

applied and continuously improved. For its part, Reeder Flying Service Inc. recognizes the

important role it plays in educating the public and building awareness of both the promise

and precautions that accompany the commercial deployment of this new and exciting

platform.

The UAS utilized by Reeder Flying Service Inc. is battery-powered and serves as a safe,

efficient and economical alternative to the manned aircraft traditionally utilized to obtain

aerial imagery. A grant of exemption would allow Reeder Flying Service, Inc. to contribute

to the reduction of manned aircraft needed to perform the aerial acquisition of data, video

and photographic content and subsequently reduce the volume of manned aircraft in the

NAS.

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

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

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

battery power and electric motors, the DJI Inspire 1 UAS produces no air pollution, and is

the most viable environmentally conscious alternative to the internal combustion engine

aircraft that are typically utilized for aerial video and photography. The DJI Inspire 1 UAS, 

while reducing the carbon footprint of aerial acquisitions, also sharply reduces noise

pollution, as the UAS is propelled by battery powered electric motors, rather than an

internal combustion engine.
12 | Reeder Flying Service, Inc. Petition for Exemption under Section 333

By using the DJI Inspire 1 UAS to perform aerial acquisitions, the substantial risk to life and 

property in the air and on the ground, which is usually associated with traditional manned 

aircraft flight operations, will be substantially reduced or completely eliminated. The DJI 

Inspire 1 UAS (weighing approximately 6 pounds 7.5 ounces at its maximum gross weight 

with a length of 17.3 inches and width of 17.7 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.

Previously, such services as high-resolution digital aerial real estate photography,

surveying and inspections were limited and affordable to a relatively small group of 

agencies, companies and organizations with significant operating capital. The granting of 

this exemption will enable Reeder Flying Service Inc. to change this by deploying its UAS 

in ways that make aerial photography and other UAS services accessible and affordable to

a significantly larger portion of individuals, organizations and businesses. The many new

forms of aerial content would have immediate and direct benefits to service providers,

business owners and consumers alike.

PUBLIC SAFETY

With safety as its primary operational requirement, Reeder Flying Service Inc. will plan,

conduct and manage its flight operations within very specific and well-defined operating

limitations and standards detailed in its flight operations protocols (see Attachment G). 

These protocols also clearly define the roles and responsibilities of the UAS Pilot in 

Command (UAS-PIC), the UAS Visual Observer (VO), and the client representative

working with the Reeder Flying Service, Inc. team.

In seeking this exemption, Reeder Flying Service Inc. submits that the DJI Inspire 1 UAS 

can operate safely in the NAS pursuant to FMRA Section 333, as demonstrated by the 

characteristics of the DJI Inspire 1 UAS, the pilot certification requirements, and the

specific operating limitations. The specifications of the DJI Inspire 1 UAS (see

Attachments A and B) demonstrate its safe characteristics. The DJI Inspire 1 UAS does 

not create a hazard to users of the NAS or the public, or otherwise pose a threat to national

security considering its size, weight, speed, and operational capability. Many of the

functional capabilities and features of the DJI Inspire 1 UAS enable it to be operated in a

highly controlled, precise and safe manner.

The DJI Inspire 1 UAS autonomous flight and navigation modes enable it to remain within a 

defined operational area. Also, the DJI Inspire 1 UAS may be operated in both manual and 

fully autonomous flight modes. A complete description of the flight and navigational modes

of the DJI Inspire 1 UAS is provided on pages 12-17 and 45-50 of the DJI Inspire 1 User

Manual v1.4 (see Attachment B).

The DJI Inspire 1 UAS includes automatic return-to-home-point or hover functionality in the 

event of loss of the control link or navigation. When the control ink is lost, the DJI Inspire 1 

UAS will remain stationary, in flight, for 3 seconds or more. If, after 3 seconds, the DJI 

Inspire 1 UAS does not reacquire control link data from the ground control station/remote 

controller, the UAS will assume that the control link is lost and will return to the home 

position (i.e., failsafe mode) via GPS, and will descend to the takeoff position and

shutdown.

A complete description of the failsafe functions of the DJI Inspire 1 is provided on pages

13-15 of the DJI Inspire 1 User Manual (see Attachment B).
13 | Reeder Flying Service, Inc. Petition for Exemption under Section 333

Whether conducting site and land surveys, inspecting infrastructure, helping to protect the

public or acquiring aerial imagery and video, Reeder Flying Service Inc. UASs will be

providing its customers with more accurate and timely information. The real-time

situational awareness and improved decision-making this achieves will enable Reeder 

Flying services’ customers and clients to communicate with and more safely serve and

support their respective constituents.

Strict adherence to specific flight operations protocols (see Attachment G), the use of the

DJI Inspire 1 UAS configured with significant safety functionality, the acquisition of an 

accurate understanding of both the flight operations area and its adjacencies using Reeder 

Flying Service Inc.’s Site Safety and Planning Template (see Attachment L), and the use of 

Reeder Flying Services’ On-Site Client Safety Briefing (see Attachment N) will provide a

level of safety and oversight that is in complete alignment with the FAA’s mission to

“provide the safest, most efficient aerospace system in the world.” [FAA online document,

Public Guidance for Petitions for Exemption Filed under Section 333. Rev. 9/25/2014]

PRIVACY

All flights will occur over private or controlled-access property with the property owner’s or 

controlling authority’s prior consent and knowledge. Aerial photography and video capture 

will be of people who have provided their written consent to being photographed or have

been authorized to be in the area where flight operations are taking place. (see

Attachments O and P) Establishing and maintaining tight controls over access to the flight

operations area will minimize privacy issues.

Similar to the manned aerial acquisition flight operations that have been conducted for 

decades, Reeder Flying Service Inc.’s proposed operation of the DJI Inspire 1 UAS will not 

implicate any privacy issues. Specifically, the DJI Inspire 1 UAS will be operated under 

detailed operational protocols designed to ensure client or property owner involvement as

well as local law enforcement notification. Flight operations will be conducted in

accordance with Federal Aviation Regulations, including the altitude restrictions as defined 

in this Grant of Exemption.

Reeder Flying Service Inc. has developed a proprietary work-site planning template and 

site briefing plan (see Attachments L and M) that will be completed and reviewed with the

client’s onsite representative prior to the commencement of any operation or project. This

detailed diagram of the operational environment will provide the PIC, VO(s), Safety Officer,

and any other designated support and security personnel with a full understanding of the

site or subject’s structural characteristics, layout, topography, adjacencies, and all

significant and relevant natural and manmade features within the operational area. The

template will also be used by Reeder Flying Service Inc. personnel to gain a clear picture

of any area or condition immediately adjacent to or near the operational area. This will

enable Reeder Flying Service Inc. to acquire a detailed understanding of the larger 

geographical context surrounding the flight operations area and review relevant factors with

the client before the commencement of any work or service.
14 | Reeder Flying Service, Inc. Petition for Exemption under Section 333

CONDITIONS AND LIMITATIONS

As set forth in Reeder Flying Service Inc. UAS General Operations Manual, which 

includes: All manufacturer documentation for the Inspire 1 UAS and Reeder Flying 

Service, Inc. proprietary operations documentation for all UAS operations (e.g., Flight

Operations Protocols, Flight Checklists and Operating Procedures, Pilot Flight Log, UAS 

Flight Log, Client Site Safety and Planning Template, Pre-Flight Operations On-Site Client 

Safety Briefing, and Permission to Conduct Onsite Flight Operations Consent Form), the

applicant proposes the following limitations and conditions:

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 UAS-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 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
15 | Reeder Flying Service, Inc. Petition for Exemption under Section 333

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, or recreational 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 (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 | Reeder Flying Service, Inc. Petition for Exemption under Section 333

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 FAA-published

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 

(N−Number) markings in accordance with 14 CFR part 45, Subpart C. Markings must be

as large as practicable.

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
17 | Reeder Flying Service, Inc. Petition for Exemption under Section 333

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.

c. Operations nearer to the PIC, VO, operator trainees or essential persons do not present an 

undue hazard to those persons per § 91.119(a).

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.

5. LIST OF PROPRIETARY FLIGHT OPERATIONS, STANDARDS, PROTOCOLS AND

PROCEDURES DOCUMENTATION

As noted earlier, Reeder Flying Service, Inc.’s UAS General Operations Manual (UAS 

GOM) includes all manufacturer’s documentation for the DJI Inspire 1 UAS, as well as a 

number of flight operations protocols, requirements and procedures Reeder Flying 

Service, Inc. considers proprietary. Together, these documents governing the planning,

management and execution of all Reeder Flying Service, Inc. flight operations. The UAS 

GOM is reviewed and updated on a regular basis to ensure it is accurate, current and 

reflects any new FAA requirement, change of standard and any improvement or addition to 

its flight operations Reeder Flying Service, Inc. considers to be in its clients’ and the 

public’s best interest.

Ten of the sixteen attachments included (see Attachments G, H, I, J, K, L, M, N, O, P) and 

referenced in the request for exemption contain commercial proprietary information that 

Reeder Flying Service, Inc. has chosen not to share with others except under appropriate 

confidentiality agreements at this time. These attachments contain operating conditions, 

graphics and procedures that have been developed exclusively by Reeder Flying Service, 

Inc., and that are not available to the public. Reeder Flying Service, Inc. is respectfully 

requesting that these attachments be treated as proprietary information pursuant to 14 

C.F.R. Section 11.35, and maintains that they are protected from release under the 

Freedom of Information Act. See 5 U.S.C. 552 et seq.

6. THE APPLICABLE LEGAL STANDARD UNDER SECTION 333

Reeder Flying Service submits that grant of this exemption application advances the 

Congressional mandate in Section 333 of the Reform Act to accelerate the introduction of 

UASs into the NAS if it can be accomplished safely. This law directs the Secretary of 

Transportation to consider whether certain UASs 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 UASs do not create a 

hazard to users of the NAS, the public, or pose a threat to national security in light of the 

following:
18 | Reeder Flying Service, Inc. Petition for Exemption under Section 333

• The UAS’s 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 PIC.

Reform Act § 333 (a) (1). 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.” Id. § 333 (c).

The Federal Aviation Act 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, from the requirement that all civil aircraft must have a current

airworthiness certificate and those regulations requiring commercial pilots to operate

aircraft in commercial service:

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

under subsection (a) or (b) of this section or any of sections 4470244716 of this title if the 

Administrator finds the exemption is in the public interest.

The grant of the requested exemption is in the public interest based on the clear direction

in Section 333 of the Reform Act; the additional authority 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 and cost savings associated with

use of UASs for aerial videography/photography, the reduction or elimination of 

unregulated operators, and the safe integration of UASs. Accordingly, the applicant

respectfully requests that the FAA grant the requested exemption without delay.

CONCLUSION

As set forth herein, Reeder Flying Service Inc. seeks an exemption pursuant to 14 C.F.R.

§ 11.61 and Section 333 of the FAA Modernization and Reform Act of 2012 from the 

requirements of 14 C.F.R. 21, subpart H; 14 C.F.R. 45.23(b); 14 C.F.R. §§ 61.101(e)(4) & 

(5); 14 C.F.R. §§ 61.113(a) and (b); 14 C.F.R. § 91.7(a); 14 C.F.R. § 91.9(b)(2); 14 C.F.R. 

§ 91.103(b); 14 C.F.R. § 91.109; 14 C.F.R. § 91.119(b) and (c); 14 C.F.R. § 91.121; 14 

C.F.R. § 91.151; 14 C.F.R. §§ 91.203(a) and (b); 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. § 91.409(a)(1) and (2); and, 14 C.F.R. 

§§ 91.417(a) and (b) to commercially operate an Unmanned Aircraft System (UAS) for the 

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

States.

Approval of the exemption allowing commercial operations of Reeder Flying Service Inc. 

UAS will increase safety by permitting an operator to conduct a service safely by adhering

to the prescribed guidelines. The exemption will also encourage the education of UAS 

operators and the adoption of FAA guidelines and approval for commercial UAS operations

as pertains to Reeder Flying Service Inc. employees and contractors. It will allow Reeder 

Flying Service Inc. to provide a service that benefits the public and local businesses. It

benefits the public through a higher level of safety of UAS operations and through a

smooth integration of UASs into the NAS. Having a pilot-owned business bridges the gap

between the advancement of UAS technology and the current practices and operations in

the NAS and with the FAA. This assists the FAA with its mission of promoting aviation

while preserving safety of aviators, the public and property. The UAS operated by Reeder 

Flying Service Inc. satisfies the criteria set forth in § 333 of the Reform Act – size, weight,

speed, operating capabilities, operation within visual line of sight, and national security –
19 | Reeder Flying Service, Inc. Petition for Exemption under Section 333

and showing an equivalent level of safety to manned aircraft flights through appropriate

pilot certification and safety-focused standards of operation. This provides more than

adequate justification for the grant of the requested exemptions allowing commercial

operations.

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 Reeder Flying Service Inc. to safely, efficiently and economically

operate the UAS commercially within the NAS.

Respectfully,

Stephen L. West

GM/Director of Operations

Reeder Flying Service Inc.

ATTACHMENTS- All attachments presented in .pdf format

DJI Inspire 1 Manufacturer Documentation:

A. DJI Inspire 1 Overview and Specifications Data Sheet

B. DJI Inspire 1 User Manual_v1.4

C. DJI Inspire 1 Safety Guidelines

D. DJI Inspire 1 Quick Start Guide

E. DJI Inspire 1 Maintenance Manual_v1.0

F. DJI Inspire 1 Intelligent Flight Battery Safety Guidelines

Reeder Flying Service, Inc. Proprietary Documentation:

G. Reeder Flying Service, Inc. UAS General Operations Manual, Ver1.0.pdf

H. Reeder Flying Service, Inc. UAS Daily Flight Log.pdf

I. Reeder Flying Service, Inc. UAS Inspection Status Form.pdf

J. Reeder Flying Service, Inc. UAS Pilot Duty and Flight Log.pdf

K. Reeder Flying Service, Inc. 50 hour/ 200 flight Inspection Form.pdf

L. Site Safety and Planning Template

M. Client Site and Operation Plan

N. Pre-Flight Operations On-Site Client Safety Briefing

O. Permission to Conduct Onsite Flight Operations Consent Form

P. Photo and Video Image Release Form