Aero Images LLC

1431 Capri Lane #5202

Weston, FL 33326

May 4th of 2015

U. S. Department of Transportation

Docket Management System

1200 New Jersey Ave., SE

Washington, DC 20590

Re: Exemption Request Under Section 333 of the FAA Reform Act and

 Part II of the Federal Aviation Regulations.

Dear Sir or Madam:

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the “Reform Act”) and 14 

C.F.R. Part II, Aero Images LLC (“AI”), operating the DJI Inspire1 Unmanned Aircraft System (“UAS” 

or “Inspire1”) seeks an exemption from the Federal Aviation Regulations (‘FARs”) listed below and 

discussed in Appendix A. Attached, as Appendix B is a summary of this request.

The requested exemption would permit commercial operation of AI’s Inspire1, which weights under 7 

lbs. and performs aerial photography and videography using onboard cameras. Applications for this 

UAS devices and associated data processing functions include residential and commercial real estate, 

event coverage, surveying, inspections and artistic endeavors. Use of the Inspire1 for aerial 

photography reduces the need to operate conventional aircrafts. These savings result in enhanced 

efficiency and productivity for the affected activities, as well as environmental benefits.

Operation under the exemption will be subject to strict operating requirements and conditions to ensure 

at least an equivalent level of safety to currently authorized operations using manned aircrafts and under 

conditions as may be modified by the FAA as required by Section 333.

As described more fully bellow, the requested exemption would authorize commercial operations of 

aerial surveys using the Inspire1, which at under 7 lbs. is small in size. The Inspire1 will be operated 

under controlled conditions at low altitude in airspace that is limited in scope, as described more fully 

herein; it will have automated control features, as described bellow. The Inspire1 will be operated by

Miguel S. De Felice, (“owner and chief pilot of Aero Images LLC”), who holds an Airline Transport 

Pilot Certificate # 2817924, a current First Class Medical Certificate with around 9200 total hours 

logged and who has performed more than 30 flights with the Inspire1 including training. 

Aero Images L.L.C, respectfully submits that because this small, unmanned aerial vehicle (“the 

Inspire1”) will be used in lieu of comparatively hazardous operations now conducted with fixed wing 

and rotary conventional aircrafts, the FAA can have confidence that the operations will achieve a greater 
level of safety. Approval of this exemption would thereby enhance safety and fulfill the Secretary of 

Transportation’s (The FAA Administrator’s) responsibilities under Section 333 (c) of the Reform Act to 

“ establish requirements for the safe operation of such aircraft systems in the national airspace system.”

The name and address of the applicant are:

 

Company: Aero Images LLC

Attn: Miguel S. De Felice

Phone: 954-599-2749

Email: aeroimagesllc@gmail.com

Address: 1431 Capri Lane #5202

 Weston, FL 33326

The regulations from which the exemption is requested are as follow:

 14 C.F.R. Part 21

 14 C.F.R. 45.23 (b)

 14 C.F.R. 61.113 (a) & (b)

 14 C.F.R. 61.133 (a)

 14 C.F.R. 91.7 (b)

 14 C.F.R. 91.9 (b)(2)

 14 C.F.R. 91.109 (a)

 14 C.F.R. 91.119

 14 C.F.R. 91.151 (a)

 14 C.F.R. 91.203 (a) & (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. 91.417 (a)

Appendix A discusses each rule listed above and explains why exemptions pursuant to the proposal set 

forth in this letter are appropriate, provided an equivalent level of safety, and are in the public interest.

THE APPLICABLE LEGAL STANDARD UNDER SECTION 333

AI submits that grant of this exemption application for use of the Inspire1 in precision aerial surveys 

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

of UASs into the national airspace system (“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 332of 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 or the public or pose a threat to national security in light of the following:

 The UASs size, weight, speed, and operational capability;

 Operational of the UAS in close proximity to airports and populated areas; and
 Operation of the UAS within visual line of sight of the operator.

Reform Act. 333(a)(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 40101of 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 44702-44716 of this title if the Administrator finds 

the exemption is in the public interest.

49 USC 44701(f) See also 49 USC 44711(a); 49 USC 44704; 14 CFR 91.203(a)(1).

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 saving associated with transitioning the UASs for aerial survey 

photography. Accordingly, the applicant respectfully requests that the FAA grant the requested 

exemption without delay.

Airworthiness of the Inspire1

A critical element of the exemption application involves evidence of the airworthiness of the Inspire1.

AI believes that it is in compliance with the requirements of Order 8130.34C, Airworthiness 

Certification of Unmanned Aircraft System and Optionally Piloted Aircraft, in its use of systems 

developed by DJI. The Inspire1 has a high degree of redundancy and numerous safety features, 

including:

 Return-to-home failsafe in the event of a loss of communications

 Configurable limitations for area of operation and altitude

 Configurable limitations for vertical and horizontal speeds

 High visibility lighting system

The criteria set forth in the Order specify the substantive showings of the device’s safety and fitness for 

operation to ensure that the FAA has sufficient basis to evaluate the aircraft’s safety.

Mandatory Operating Conditions

Grant of the exemption to Aero Images LLC will be subject to the following mandatory conditions, 

which are based upon operating conditions set forth for operation of UAS by public entities pursuant to 

Certificates of Authorization, with additional restrictions:

 All operations to occur in Class G airspace.

 Operations to avoid congested or populated areas, which are depicted in yellow on VFR charts
 Operations to be conducted over private or controlled-access property.

 Permission from land owner/controller required before commencing any flight.

 Operations to occur during Visual Flight Rules Meteorological Conditions (VMC)

 Aircraft to remain within Visual Line of Sight (VLOS).

1. VLOS guaranteed with a cylinder operation around operator of 1⁄2 nautical miles (NM)

2. Cylinder walls may be expanded by observer with ability to control aircraft

 Operations to occur during daylight hours

 Altitude restricted to 400 feet Above Ground Level (AGL)

 All operations conducted in vicinity of airport to remain more than 2.5 NM from centerline 

azimuth of runway centerline measured from runway thresholds.

 Operator will file a NOTAM for each flight as required 

 All required permissions and permits would be obtained from territorial, state, county or city 

jurisdiction, including local law enforcement, fire, or other appropriate governmental agencies.

Operator Requirements

AI respectfully proposes that operator requirements should take into account the characteristics of the 

particular UAS. Certain UASs, such as the AIs Inspire1, are characterized by a high degree of preprogrammed control and various built-in technical capabilities that limit the potential for operation 

outside of the operating conditions set forth above.

The Inspire1 has a semi-autonomous navigation and control system comprised of a Ground Control 

Station (GCS) and autopilot system. All flights are pre-programmed with GPS guidance and do not 

require human intervention. Flight mission area and routing cannot be changed after launch. Flights are 

not directed by positive manual control, nor are evasive maneuvers. In the case of unplanned events, the 

operator inputs pre-programmed evasive maneuvers from the control unit and the control units executes 

that maneuver. Pre-programmed operator interventions include diversion to the right; initiation of 

holding at present position; suspension of mission; fly back to launch point; fly to point and hold; abort 

mission and land; and emergency power cut off and land (Flight Termination System). 7 Additional 

automated safety functions and safety-enhancing features of the Inspire1 include the following:

 Autopilot detection of lost GPS or of insufficient satellites initiates an immediate vertical 

landing, unless overridden by pilot in command.

 Low power on the aircraft triggers escalating alarms at GCS at 35% and 10% levels.

 If the autopilot detects a lost-link to the GCS for longer than 30 seconds, return-to-home 

sequence initiates.

 The Inspire1 is inherently unstable, so auto-pilot failure will result in a rapid exit from flight.

 Aircraft has an on-board failsafe that limits vertical speed to approximately 6 m/s (configurable).

 The aircraft, weighing less than 7 lbs., fully loaded, is constructed of composite material 

intended to absorb impact energy.

 The motors are driven by pulse width modulated signals, not analog signals.

Given this safety features, Aero Images proposes that operators of the Inspire1 should not be required to 

hold a commercial or private pilot certification, although the owner-operator and chief pilot of AI, holds 

an ATPL certification. Instead, operators should be required to:
 Have successfully completed, at a minimum, FAA private pilot ground instruction and passed 

the FAA Private Pilot written examination or FAA-recognize equivalents.

 Have successfully demonstrated capability to operate UAS in accordance with manufacturer 

standards.

AI notes that the FAA has found that safety factors permitted operations of UASs by operators with 

these qualifications in the case of operations pursuant to public COAs when the mandatory operating 

conditions specified above were present. See Federal Aviation Administration, Notice N-8900.227, 

Unmanned Aircraft System (UAS) Operational Approval, at 20-21 (July 30, 2013). The FAA has the 

statutory authority to grant exemptions to the requirements for and privileges associated with the grant 

of airmen’s certificates. 49 USC 44701 (f).

In summary, applicant seeks and exemption from the FARs set forth above and in Appendix A to allow 

commercial operations of a small-unmanned vehicle conducting precision aerial surveys.

Approval of the exemption allowing commercial operations of the Inspire1 for precision survey work 

will enhance safety by reducing risk. Conventional aerial survey operations, using jet or piston-powered 

aircraft present risks associated with vehicles that weight in the neighborhood of 5,000 to 7,000 lbs., or 

more, carry large quantities of fuel, passengers, and, in some cases, cargo. Such aircraft must fly to and 

from the survey location. In contrast, an Inspire1 weighing less than 7 lbs. and powered by smart 

batteries eliminates a portion of that risk given to reduce mass and lack of combustible fuel carried on 

board. The Inspire1 is carried to the survey location, not flown there. The Inspire1 will carry no 

passengers or crew and, therefore, will not expose any individuals to the risks associated with manned 

aircraft flights.

Additionally, no national security issue is raised by the grant of the requested exemption. Given the size, 

load carrying capacity, speed at which it operates, and the fact that it carries no explosives or other 

dangerous materials, the Inspire1 poses no threat to national security.

The operation of the Inspire1, weighing less than 7 lbs., for precision surveys in accordance with the 

strict conditions outlined above, will provide an equivalent level of safety supporting the grant of the 

exemptions requested herein, including exempting Aero Images LLC from the requirements of Part 21.

The Inspire1’s satisfaction of the criteria set forth in Section 333 of the Reform Act—size, weight, 

speed, operating capabilities, lack of proximity to airports and populated areas, operating within visual 

line of sight, and national security—and its showing of an equivalent level of safety as it may relate to 

the requirement of a pilot’s license, provide more than adequate justification for the grant of the 

requested exemptions allowing commercial operation of the Inspire1 in the commercial precision aerial 

survey business. 

Very Respectfully,

Miguel S. De Felice

Aero Images LLC