1

October 7, 2015

Thomas Hamilton

CEO

Red Sea Pictures

6755 Ferri Circle

Port Orange, FL 32128

U.S. Department of Transportation 

Docket Management System

1200 New Jersey Ave S.E. 

Washington, D.C. 20590 

Re: Request for Exemption under Section 333 of the FAA Modernization and 

Reform Act of 2012 and Part 11 of the Federal Aviation Regulations from Certain 

Provisions of 14 C.F.R. for Thomas Hamilton, dba Red Sea Pictures.

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 11, Thomas Hamilton (dba Red Sea Pictures) files this 

petition for exemption on behalf of Red Sea Pictures (“RSP”), an operator of Small 

Unmanned Aircraft Systems (“UAs”) for aerial cinematography. Specifically, petitioner 

seeks an exemption from the Federal Aviation Regulations (“FARs”) listed in Appendix 

A 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 in a 

grant of this petition. This request is substantially similar to other data collection petitions 

previously approved, and should be considered under the expedited summary grant 

procedure.

Approval of the exemption for petitioner will allow commercial operation of the 

DJI Inspire 1 in Class G airspace nationwide unless otherwise prescribed by an Air 

Traffic Organization (ATO) issued COA. This UA has been previously approved for 

commercial operations in Exemption Nos. 11204, 11224, 11254, 11279, 11280, 11288, 

11295, 11301, 11303, 11313, 11314, 11318, 11323, 11327, 11336, 11342, 11359, 11377, 

11384, 11385, and 11394. The UA covered by this petition is a small battery-powered 

craft, weighing approximately 6.5 lbs., inclusive of battery and payload. Operation of the 

UA under the strict conditions proposed below will provide an equivalent level of safety, 

as Congress intended, while still allowing commercial operations. Operations using these 

UAs are far safer than conventional operations conducted with helicopters and fixedwing aircraft that weigh thousands of pounds, carry highly flammable fuel, and operate in 

close proximity to the ground, trees, infrastructure, and people. 

Congress directed the FAA to consider seven factors in deciding whether to 

approve Section 333 exemption petitions - size, weight, speed, operational capability, 

proximity to airports, proximity to populated areas, and operation within visual line of 
2

sight. In this case, each factor supports the exemption request. In particular, the UA is 

small, and will operate at slow speeds and close to the ground. It will be able to more 

safely and efficiently conduct operations that would otherwise involve risk of injury or 

death. The substantial increase of safety and decrease of risk to human life and to 

property weighs heavily in favor of granting the exemption.

Additionally, please consider the extensive professional aviation experience of the 

petitioner, as outlined below, in consideration of this request.

For your ease in reviewing this petition, please refer to the table of contents which 

begins on page 3. If I can provide any additional information to assist your understanding 

or review of this document, please do not hesitate to contact me at 518-409-0479, or via 

email at redseapictures@gmail.com.

Thank you,

Thomas Hamilton

CEO Red Sea Pictures

FAA Airline Transport Pilot License #2345545

Type rated in:

A-320 (Airbus 319/320/321 series)

MD-11 (McDonnell Douglas MD-11)

DC-8 (Douglas DC-8)

CL-604 (Bombardier Challenger 604)

CE-500 (Citation Jet)

N-265 (Rockwell Sabreliner)

CFII-MEL Certified Flight Instructor, Instrument, Multi Engine

FEX Flight Engineer Turbojet (Boeing 747-200)

First Class Medical Certificate

Tel: 518-409-0479
3

Table	of	Contents	

I. Publishable Summary....................................................................................5 

II. Petitioner’s Contact Information.................................................................5 

III. Proposed Operations ................................................................................... 6 

1. The UAs ..................................................................................................... 6 

2. The Crew .................................................................................................... 6 

3. Flight Conditions......................................................................................... 7 

4. Flight Operations ........................................................................................ 7 

IV. Aircraft and Equivalent Level of Safety ................................................................ 8

VI. Proposed Conditions of the Exemption.................................................................. 9

VI. Privacy ..................................................................................................................... 13

VII. Public Interest and Safety...................................................................................... 13

VIII. Regulations from Which Exemption is Requested ...................................... 14

Appendix A: FARs as to which RSP wishes the same determination to be made as has 

been made previously.
4

Exhibit	List: Links	to	Latest	Official	Manufacturer’s	Documentation	-	DJI

Exhibit 1: Inspire 1 Quick Start Guide

http://download.dji-innovations.com/downloads/inspire_1/en/Inspire_1_Quick_Start_Guide_v1.4_en.pdf

Exhibit 2: Inspire 1 User Manual

http://download.dji-innovations.com/downloads/inspire_1/en/Inspire_1_User_Manual_v1.4_en.pdf

Exhibit 3: Safety Guidelines

http://download.dji-innovations.com/downloads/inspire_1/en/Inspire_1_Safety_Guidelines_en.pdf

Exhibit 4: Disclaimer and Warning 

http://download.dji-innovations.com/downloads/inspire_1/en/Inspire_1_Disclaimer_and_Warning_en.pdf

Exhibit 5: Intelligent Flight Battery Safety Guidelines

http://download.dji-innovations.com/downloads/inspire_1/en/Intelligent_Flight_Battery_Safety_Guidelines__en.pdf

Exhibit 6: Inspire 1 Maintenance Manual

http://download.dji-innovations.com/downloads/inspire_1/en/Inspire_1_Maintenance_ManualV1.0_en.pdf

Exhibit 7: Inspire 1

http://www.dji.com/product/inspire-1

Exhibit 8: Inspire 1 Features

http://www.dji.com/product/inspire-1/feature

Exhibit 9: Inspire 1 Specifications

http://www.dji.com/product/inspire-1/spec
5

I. Publishable	Summary	

Pursuant to 14 C.F.R. §11, the following summary is provided for publication in the 

Federal Register, should it be determined that publication is needed: 

Petitioner seeks an exemption from the following rules: 

14 C.F.R 21(h); 14 C.F.R. 43.7; 14 C.F.R. 43.11; 14 C.F.R. 45.11; 14 C.F.R. 45.27; 14 

C.F.R. 45.29; 14 C.F.R. 91.7(a); 14 C.F.R. 91.9(b)(2); 14 C.F.R. 91.9(c); 14 C.F.R. 

91.103(b)(2); 14 C.F.R. 91.105; 14 C.F.R. 91.109; 14 C.F.R. 91.113(b); 14 C.F.R. 91.119 

(c); 14 C.F.R. 91.121; 14 C.F.R. 91.151(a); 14 C.F.R. 91.203(a) and (b); 14 C.F.R. 

91.215; 14 C.F.R. 91.403; 14 C.F.R. 91.405(a); 14 C.F.R. 91.407(a)(1); 14 C.F.R. 

409(a)(1) and (2); and 14 C.F.R. 91.417(a) and (b) to operate commercially small 

unmanned aircraft systems (UAs) (6.5 lbs. or less).

Approval of the exemption requested by petitioner will allow commercial operation of 

the DJI Inspire 1 for the purpose of aerial cinematography in Class G airspace 

nationwide, unless otherwise prescribed by an ATO-issued COA. The requested 

exemption should be granted because operation of a small UA weighing approximately 

6.5 lbs. (2.9 kg.), inclusive of battery and payload, conducted in the strict conditions 

outlined below, will provide an equivalent level of safety, while still allowing 

commercial operations. The lightweight aircraft covered by the exemption are far safer 

than conventional operations conducted with helicopters and fixed-wing aircraft 

weighing thousands of pounds and carrying highly flammable fuel, and operating in close 

proximity to the ground and people. The seven factors Congress directed the FAA to 

consider when approving Section 333 exemption petitions - size, weight, speed, 

operational capability, proximity to airports, proximity to populated areas, and operation 

within visual line of sight – each support the request. In particular, the aircraft are small, 

and will operate at slow speeds, and close to the ground. The substantial increase of 

safety and decrease of risk to human life, coupled with the low risk use of UAs to 

conduct these operations, weigh heavily in favor of granting the exemption. 

Petitioner’s	Contact	Information	

Thomas Hamilton

CEO

Red Sea Pictures

6755 Ferri Circle

Port Orange

FL 32128

Tel: 518-409-0479

Email: redseapictures@gmail.com
6

III.	Proposed	Operations	

A. The	UAs	

The requested exemption will permit petitioner to operate the DJI Inspire 1. The Inspire 1 

has been previously approved for commercial operation in Exemption Nos. 11204, 

11224, 11254, 11279, 11280, 11288, 11295, 11301, 11303, 11313, 11314, 11318, 11323, 

11327, 11336, 11342, 11359, 11377, 11384, 11385, and 11394.

This petition, along with Exhibits 1-9 which include the supporting documentation of the 

UA, are hereinafter referred to as the “operating documents.” The specific conditions of 

the proposed exemption that relate to the characteristics of the UAs are numbers 1, 5, and 

16-20 in Section VI below. Each has been adopted or imposed by the FAA in numerous 

previous grants of Section 333 exemption petitions. The Inspire 1 has the ability to hover 

and move in the vertical and horizontal planes simultaneously.

The Inspire 1 has the following specifications or equivalent: 

Airframe: DJI Inspire 1

Control system: internal to the Inspire 1. This includes the main controller (MC), which 

receives the battery voltage, capacity, and current, the internal measurement unit (IMU), 

which receives telemetry data, compass, and GPS.

Maximum speed: 43 knots

Weight, inclusive of battery and technical payload: 6.5 lbs. (2.9 kg.)

Transmitter (Tx): DJI Inspire Remote Control

Receiver (Rx): internal to the control system

Motors: DJI 3510

Propellers: 13” x 4

Combined data and video link: HD Lightbridge

Gimbal: Zenmuse X3

Batteries: Lithium Polymer 6S High voltage battery with 4500-5700 mAh capacity

Telemetry display: DJI Pilot App

Automatic return to home procedure: If Tx signal is lost for more than three seconds and 

the UA is under 65 ft. (20 m.) AGL, the UA will rise to 65 ft. AGL, travel horizontally to 

the pre- designated home spot, hover for 15 seconds, then land. If the UA is above 65 ft. 

AGL, travel horizontally to the pre-designated home spot, hover for 15 seconds, then 

land.

B. The	Crew

The crew will consist of Thomas Hamilton, ATP, pilot in command (PIC), and a visual 

observer (VO). The PIC and VO will have been trained in operation of UAs generally 

and received up-to-date information on the UA to be operated pursuant to this grant. The 

PIC will receive Inspire-specific training to ensure proficiency on the platform.

The specific conditions of the proposed exemption that relate to the training and 

characteristics of the crew are numbers 3 and 6-9 in Section V below. Each has been 
7

adopted or imposed by the FAA in numerous previous grants of Section 333 exemption 

petitions. 

C. Flight	Conditions

The UA will be used for aerial cinematography in Class G airspace (unless otherwise 

prescribed by an ATO-issued COA) under 200 feet above ground level (“AGL”) and 

under controlled conditions over restricted property. Petitioner will work with the local 

FSDO when planning operations. Petitioner will only operate its UA in visual 

meteorological conditions (VMC). The UA will at all times be no less than 500 feet 

below and no less than 2,000 feet horizontally from a cloud, and petitioner will not 

conduct operations unless visibility is at least 3 statute miles from the PIC. The flight 

crew will always make a safety assessment of the risk of every operation, and will only 

operate when it is determined that no hazards are present.

Additionally, petitioner will follow DJI’s guidelines for flight conditions. These are 

found in Exhibit 2, beginning on page 45 of that document.

The specific conditions of the proposed exemption that relate to the flight conditions in 

which the UA will be operated are numbers 2, 4, 16, and 28-29 in Section V below. Each 

has been adopted or imposed by the FAA in numerous previous grants of Section 333 

exemption petitions.

D. Flight	Operations	

The purpose of the UA flights for which exemption is requested will be for aerial 

cinematography. Every UA flight will use at minimum a two person flight crew: a PIC 

and a VO.

Petitioner will limit flights to 200 ft. AGL, and requests the FAA to allow it to operate no 

closer than 175 ft. from nonparticipating individuals when operating at or below 65 ft. 

AGL. Petitioner will be able to maintain the safety of nonparticipants while decreasing 

the nonparticipant parameter, by applying the same ratio the FAA has previously 

determined to be safe.

Petitioner anticipates that every flight, even one that is planned to be at 30 ft. AGL, may 

rise to 65 ft. AGL if the automatic return-to-home program is activated.

Petitioner has selected the 175 ft. “nonparticipant parameter” by looking at the FAA’s 

“safety ratio” for previous Section 333 approvals. Under the new “blanket 200 ft. COA” 

procedure, an approved operator may operate their UA up to 200 ft. AGL while keeping 

nonparticipants 500 ft. away from operations, giving the following ratio:

Nonparticipant parameter 

Maximum height AGL = Safety Ratio

500 ft./200 ft. = 2.5
8

By multiplying the maximum height AGL of an operation by 2.5, petitioner will maintain 

this same “safety ratio” previously approved by the FAA. For example, if an operation 

will have a maximum AGL of 100 ft., petitioner will require nonparticipants to remain at 

least 250 ft. from the operational area.

For operations that will take place at or below 65 ft. AGL, application of the “safety 

ratio” would require nonparticipants to remain at least 162.5 ft. from the operational area. 

In an abundance of caution, petitioner will increase this distance an additional 12.5 ft. to 

maintain a 175 ft. perimeter from the operational area. Regardless of this minimum, 

petitioner will require a greater perimeter should it determine one is necessary for a given 

operation.

Before conducting an operation, the flight crew will examine the operational area to 

identify at least two potential safe emergency landing areas, should nonparticipating 

individuals enter into the flight area.

Additionally, petitioner will follow DJI’s guidelines for flight operations, including DJI’s 

preflight checklist. Please refer to the following exhibits: 

Exhibit 2 beginning on page 49 of that document 

Exhibit 3

Petitioner will follow DJI’s maintenance guidelines found in Exhibit 6. Only individuals 

who have experience and training on the Inspire 1 system will be approved to conduct 

inspection and maintenance. If it is determined that the UA requires more specific 

maintenance than can be conducted in-house, petitioner will send the UA to the 

manufacturer or manufacturer-certified repair center to be repaired.

The specific conditions of the proposed exemption that relate to flight operations are 

numbers 11-12, 17-25, and 32-35 in Section V below. Each has been accepted or 

imposed by the FAA in numerous previous grants of Section 333 exemption petitions.

IV. Aircraft	and	Equivalent	Level	of	Safety	

Petitioner proposes that the exemption apply to UAs that have the characteristics and that 

operate with the limitations proposed herein. These limitations provide for a level of 

safety at least equivalent to or higher than manned aircraft operations under the current 

regulatory structure. Section V below identifies the limitations and conditions to which 

petitioner agrees to be bound when conducting commercial operations under a grant of 

this petition. Appendix A contains a matrix connecting (i) the specific proposed condition 

with (ii) the FAR provision for which it provides equivalent level of safety and (iii) one 

or more recent Section 333 exemption grants in which the FAA recognized this 

equivalent level of safety. 

Approval of the commercial operations outlined in this petition presents no national 

security issue. Petitioner is willing to require its PICs to undergo a background check, 

including the proposed Transportation Security Administration Vetting process, to ensure 

that no national security threat is present. Operation and Certification of Small 
9

Unmanned Aircraft, 80 Fed. Reg. 9543 at 9572 (proposed Feb. 23, 2015 (to be codified at 

14 C.F.R. Parts 21, 43, 45, et al.). 

V. Proposed	Conditions	of	the	Exemption	

1. The UAs, including battery and technical payload will weigh no more than 

approximately 6.5 lbs. (2.9 kg.).

2. UA operations under this exemption will be limited to conducting operations for 

the purpose of utility and infrastructure inspections in Class G airspace 

nationwide, unless otherwise prescribed by an ATO issued COA. 

3. Flights will be operated within line of sight of a PIC and VO.

4. Flights will be operated at an altitude of no more than 200 feet AGL, as indicated 

by the procedures specified in the operating documents. All altitudes reported to 

ATC must be in feet AGL. 

5. The UA will not be flown at an indicated airspeed exceeding 43 knots.

6. Minimum flight crew for each operation will consist of the UA PIC and a VO.

7. The PIC will have completed UA-specific training provided by the manufacturer 

prior to commercial operations. 

8. The petitioner will not permit any PIC to operate unless the PIC meets its 

qualification criteria and demonstrates the ability to safely operate the UA in a 

manner consistent with how the UA 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 will be logged in a manner consistent with 14 CFR §61.51(b). 

A record of the PIC training will be documented and made available upon request 

by the Administrator. Training operations will only be conducted during 

dedicated training sessions. During training, proficiency, and experience-building 

flights, all persons not essential for flight operations will be considered 

nonparticipants, and the PIC will operate the UA with appropriate distance from 

nonparticipants in accordance with 14 CFR § 91.119.

9. The VO will not perform any other duties beyond assisting the PIC with seeing 

and avoiding other air traffic and other ground based obstacles/obstructions, and 

will not be permitted to operate the camera or other instruments.

10. The PIC will be designated before the flight and will not be allowed to transfer his 

or her designation for the duration of the flight. The PIC will ensure that the VO 

can perform the functions prescribed in these conditions and the operating 

documents. 
10

11. A briefing will be conducted in regard to the planned UA operations prior to each 

day’s activities. It will be mandatory that all personnel who will be performing 

duties in connection with the operations be present for this briefing.

12. Prior to each flight, the PIC will inspect the UA, including the Ground Control 

Station, to ensure it is in a condition for safe flight. If the inspection reveals a 

condition that affects the safe operation of the UA, the PIC will not operate the 

UA until the necessary maintenance has been performed and the UA is found to 

be in a condition for safe flight. All maintenance and alterations will be properly 

documented in the aircraft records.

13. Petitioner will conduct a functional flight test on any UA that has undergone 

maintenance or alterations that affect the UA operation or flight characteristics, 

e.g. replacement of a flight critical component. The PIC who conducts the 

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

14. The petitioner will carry out its maintenance, inspections, and record keeping 

requirements, in accordance with the UA manufacturer’s aircraft/component, 

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

forth in the operating documents. Maintenance, inspection, alterations, and status 

of replacement/overhaul component parts will be noted in the aircraft records, 

including total time in service, description of work accomplished, and the 

signature of the authorized person returning the UA to service. The authorized 

person will make an entry in the aircraft record of the corrective action taken 

against discrepancies discovered between inspections.

15. The UA will be operated within visual line of sight (VLOS) of the PIC and VO at 

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

device other than corrective lenses. PIC and VO will at all times be able to 

communicate verbally. They will not be permitted to use electronic messaging or 

texting to communicate during flight operations.

16. The PIC will not begin a flight unless (considering wind and forecast weather 

conditions) there is enough power to fly at normal cruising speed to the intended 

landing point and prepare to land with at least 25% battery power remaining.

17. Actual total flight time for each operational flight will result in no less than a 25% 

battery reserve.

18. The UA will have the capability to abort a flight in case of unexpected obstacles 

or emergencies. 

19. The UA will be programmed so that if it loses communications or loses its GPS 

signal, it will return to a pre-determined location within the planned operating 

area and land or be recovered in accordance with the operating documents 
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20. If the UA and its radio control link disconnect during flight, the system’s failsafe 

protection will be triggered and the multirotor will return to home and land 

automatically, rather than flying off uncontrollably or landing at an unknown 

location.

21. The operating documents required under 14 CFR §§ 91.9 and 91.203 will be 

maintained and available to the PIC at the Ground Control Station of the UA any 

time the UA is operating. These documents will be made available to the 

Administrator or any law enforcement official upon request. If a discrepancy 

exists between the conditions and limitations in the exemption grant and the 

procedures outlined in the operating documents, the grant conditions and 

limitations will take precedence and will be followed. Otherwise, the petitioner 

will follow the procedures outlined in its operating documents. If it updates or 

revises its operating documents, it will present updated and revised documents to 

the Administrator upon request. If the petitioner determines that any update or 

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

the Petitioner will petition for an amendment to the grant of exemption.

22. Petitioner will obtain written and/or oral permission from the 

landowners/authorized agents of the landowners over which flights will be 

conducted. 

23. Petitioner will obtain all required permissions and permits from territorial, state, 

county or city jurisdictions, including local law enforcement, fire, or other 

appropriate governmental agencies. 

24. UA operations will not be conducted during night, as defined in 14 CFR § 1.1. All 

operations will be conducted under visual meteorological conditions (VMC). 

Flights will not be conducted under special visual flight rules (SVFR).

25. The petitioner will obtain an Air Traffic Organization (ATO) issued Certificate of 

Waiver or Authorization (COA) prior to conducting any operations under the 

grant of exemption. Petitioner will request a Notice to Airman (NOTAM) not 

more than 72 hours in advance, but not less than 24 hours prior to the operation. 

All operations will be conducted in accordance with airspace requirements in the 

ATO issued COA, including class of airspace, and altitude level.

26. The UA will not be operated within 5 nautical miles of tower-controlled airport 

reference point as denoted on a current FAA-published aeronautical chart unless a 

letter of agreement with that airport’s management has been obtained, and the 

operation is conducted in accordance with a NOTAM as required by the 

operator’s COA. Any letter of agreement with the airport management will be 

made available to the Administrator upon request. 
12

27. The UA will 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. 

28. All operations shall be conducted in Class G airspace or as otherwise prescribed 

in an ATO issued COA. 

29. All aircraft operated in accordance with this exemption will 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 

will be as large as practicable.

30. Before conducting operations, petitioner will ensure that the radio frequency 

spectrum used for operation and control of the UA complies with the Federal 

Communications Commission (FCC) or other appropriate government oversight 

agency requirements. 

31. The UA will remain clear and yield the right of way to all manned aviation 

operations and activities at all times. 

32. The UA will not be operated by the PIC from any moving device or vehicle.

33. Petitioner will conduct all flight operations at least 175 feet from all 

nonparticipating persons, vessels, vehicles, and structures unless one of the 

following three conditions is met: 

1. Barriers or structures are present that sufficiently protect nonparticipating 

persons from the UA and/or debris in the event of an accident. The 

petitioner will ensure that nonparticipating persons remain under such 

protection. If a situation arises where nonparticipating persons leave such 

protection and are within 175 feet of the UA, the PIC will ensure that 

flight operations cease immediately. 

2. The aircraft is operated near vessels, vehicles or structures where the 

owner/controller of such vessels, vehicles or structures has granted 

permission and the PIC has made a safety assessment of the risk of 

operating closer to those objects and determined that it does not present an 

undue hazard. 

3. Operations nearer to the PIC, VO, operator trainees or essential persons do 

not present an undue hazard to those persons per § 91.119(a).

34. Petitioner will report any incident, accident, or flight operation that transgresses 

the lateral or vertical boundaries of the operational area as defined by the 

applicable COA to the FAA's UAS Integration Office (AFS-80) within 24 hours. 

Petitioner will report accidents to the National Transportation Safety Board 

(NTSB) per instructions contained on the NTSB Web site: www.ntsb.gov. 
13

VI. Privacy	

There is little concern that the proposed flights will cause invasions of privacy. All flights 

will occur over either (a) public rights of way where there is no expectation of privacy; or 

(b) over private property with permission of the landowner/authorized agent and consent 

of participating individuals.

If data collected is made available for public view, all images containing uninvolved 

persons will be blurred or blacked-out. No attempt will be made to identify any 

individuals filmed during the flights except in cases where they are trespassing upon or 

damaging customer property, or interfering with the petitioner’s or its customers’ 

operations. 

VII. Public	Interest	and	Safety

The planned UA use will increase ground safety for aerial cinematography operations. 

This type of data collection has previously been done by manned aircraft or by 

individuals on the ground. Both are more time consuming and are more expensive than 

using a UA. Use of manned aircraft poses enhanced risk to the pilot and onboard crew, 

who would be several hundred feet in the air. Additionally, manned aircraft carry highly 

flammable fuel. 

The enhanced safety and reduced environmental impact achieved using a UA and 

carrying no passengers or crew, rather than a manned aircraft of significantly greater 

proportions, carrying crew in addition to flammable fuel, gives the FAA good cause to 

find that the UA operation enabled by this exemption is in the public interest. 

Satisfaction of the criteria provided in Section 333 of the Reform Act of 2012 – size, 

weight, speed, operating capabilities, proximity to airports and populated areas and 

operation within visual line of sight and national security – provide more than adequate 

justification for the grant of the requested exemption allowing commercial operation of 

petitioner’s UA in the utility and infrastructure inspection industries, pursuant to RSP’s 

rules of operation.

The FAA has previously approved the Inspire 1 for similar commercial operations in the 

following Exemptions:

11279 (aerial photography);

11288 (aerial photography);

11313 (aerial cinematography and photography); 

11359 (photography);

11336 (aerial photography);

11377 (aerial videography and cinematography); and 

11385 (aerial videography and cinematography). 
14

VIII. Regulations	from	Which	Exemption	is	Requested

Appendix	A:	FARs	as	to	which	RSP	wishes	the	same	determination	to	

be	made	as	has	been	made	previously.	

FAR	

Provision	

Applicable	

condition(s)	in	

Section	5	of	

petition	

FAA	Exemption	Decision	

21(h) 1, 2, 3, 4, 5, 16, 25, 

28, 29 

Nos. 11062, 11063, 11064, 11065, 11066, 11067, 

11080, 11109, 11111, 11110, 11114, 11136, 11138, 

11150, 11153, 11156, 11157, 11166, 11167, 11170, 

11171, 11172, 11174, 11176, 11177, 11178, 11184, 

11185, 11188, 11189, 11191, 11192, 11193, 11195 

43.7 13, 14 No. 11208 

43.11 12 No. 11208 

45.11 29 No. 11208 

45.27 29 No. 11188 

45.29 29 Nos. 11136, 11157, 11170, 11185, 11193 

91.7(a) 12 

Nos. 11062, 11063, 11064, 11065, 11066, 11067, 

11080, 11109, 11110, 11136, 11138, 11150, 11153, 

11156, 11157, 11158, 11160, 11161, 11166, 11167, 

11170, 11171, 11172, 11174, 11177, 11178, 11184, 

11185, 11188, 11189, 11191, 11192, 11193, 11195, 

11204 

91.9(b)(2) 22 

Nos. 11062, 11063, 11064, 11065, 11066, 11067, 

11080, 11109, 11110, 11111, 11112, 11114, 11136, 

11138, 11150, 11153, 11156, 11157, 11062, 11063, 

11064, 11065, 11066, 11067, 11080, 11109, 11110, 

11111, 11112, 11114, 11136, 11138, 11150, 11153, 

11156, 11157, 11174, 11177, 11178, 11184, 11185, 

11189, 11192, 11193, 11195 

91.9(c) 30 Nos. 11136, 11170, 11171, 11174, 11185 

91.103(b)(2) 3, 9, 15, 16, 17, 18, 

19, 20 

Nos. 11062, 11063, 11064, 11065, 11066, 11067, 

11080, 11109, 11138, 11150, 11153, 11156, 11158, 

11160, 11161, 11166, 11167, 11171, 11172, 11176, 

11177, 11178, 11184, 11185, 11188, 11188, 11189, 

11191, 11192, 11193, 11195, 11204 

91.105 6 No. 11185 

91.109 7, 8 

Nos. 11062, 11063, 11064, 11065, 11066, 11067, 

11080, 11109, 11110, 11112, 11136, 11138, 11150, 

11153, 11156, 11157, 11166, 11167, 11170, 11171, 

11174, 11177, 11184, 11185, 11189, 11191, 11192, 

11193, 11194, 11195, 11206, 11208 
15

FAR	

Provision	

Applicable	

condition(s)	in	

Section	5	of	

petition	

FAA	Exemption	Decision	

91.113(b) 3, 31 No. 11238 

91.119(c ) 4, 33 

Nos. 11162, 11163, 11164, 11165, 11166, 111080, 

111109, 11110, 11111, 11112, 11114, 11136, 11138, 

11150, 11153, 11156, 11160 11161, 11166, 11167, 

11170, 11171, 11172, 11174, 11176, 11178, 11185, 

11188, 11189, 11190, 11193 

91.121 4 

Nos. 11162, 11163, 11164, 11165, 11166, 111080, 

111109, 11136, 11138, 11150, 11153, 11156, 11160 

11161, 11166, 11167, 11170, 11171, 11174, 11176, 

11178, 11185, 11188, 11189, 11190, 11193 

91.151(a) 16, 17 

Nos. 11110, 11153, 11156, 11161; 111109, 11110, 

11112, 11136, 11138, 11150, 11153, 11156, 11160 

11161, 11166, 11167, 11170, 11171, 11172, 11174, 

11176, 11178, 11185, 11188, 11189, 11190, 11193 

91.203 (a) 

and (b) 22 

Nos. 11062, 11063, 11064, 11065, 11066, 11067, 

11080, 11109, 11110, 11111, 11112, 11114, 11136, 

11138, 11150, 11153, 11156, 11157, 11170, 11171, 

11172, 11174, 11176, 11177, 11178, 11184, 11185, 

11188, 11188, 11189, 11191, 11192, 11193, 11195 

91.215 25, 26 No. 11185, 11195 

91.403 12, 13, 14 No. 11185 

91.405(a) 12, 13, 14 

Nos. 11062, 11063, 11064, 11065, 11066, 11067, 

11080, 11109, 11110, 11111, 11112, 11114, 11136, 

11138, 11150, 11153, 11156, 11157, 11158, 11160, 

11161, 11166, 11167, 11170, 11171, 11172, 11174, 

11176, 11177, 11178, 11184, 11185, 11188, 11188, 

11189, 11191, 11192, 11193, 11195, 11204 

91.407(a)(1) 14 

Nos. 11062, 11063, 11064, 11065, 11066, 11067, 

11080, 11109, 11110, 11111, 11112, 11114, 11136, 

11138, 11150, 11153, 11156, 11157, 11158, 11160, 

11161, 11166, 11167, 11170, 11171, 11172, 11174, 

11176, 11177, 11178, 11184, 11185, 11188, 11188, 

11189, 11191, 11192, 11193, 11195, 11204 

91.409(a)(1) 12, 13, 14 

Nos. 11062, 11063, 11064, 11065, 11066, 11067, 

11080, 11109, 11110, 11111, 11112, 11114, 11136, 

11138, 11150, 11153, 11156, 11157, 11158, 11160, 

11161, 11166, 11167, 11170, 11171, 11172, 11174, 

11176, 11177, 11178, 11184, 11185, 11188, 11188, 
16

11189, 11191, 11192, 11193, 11195, 11204 

FAR	

Provision	

Applicable	

condition(s)	in	

Section	5	of	

petition	

FAA	Exemption	Decision	

91.409(a)(2) 12, 13, 14 

Nos. 11062, 11063, 11064, 11065, 11066, 11067, 

11080, 11109, 11110, 11111, 11112, 11114, 11136, 

11138, 11150, 11153, 11156, 11157, 11158, 11160, 

11161, 11166, 11167, 11170, 11171, 11172, 11174, 

11176, 11177, 11178, 11184, 11185, 11188, 11188, 

11189, 11191, 11192, 11193, 11195, 11204 

91.417(a) 12, 13, 14 

Nos. 11062, 11063, 11064, 11065, 11066, 11067, 

11080, 11109, 11110, 11111, 11112, 11114, 11136, 

11138, 11150, 11153, 11156, 11157, 11158, 11160, 

11161, 11166, 11167, 11170, 11171, 11172, 11174, 

11176, 11177, 11178, 11184, 11185, 11188, 11188, 

11189, 11191, 11192, 11193, 11195, 11204 

91.417(b) 12, 13, 14 

Nos. 11062, 11063, 11064, 11065, 11066, 11067, 

11080, 11109, 11110, 11111, 11112, 11114, 11136, 

11138, 11150, 11153, 11156, 11157, 11158, 11160, 

11161, 11166, 11167, 11170, 11171, 11172, 11174, 

11176, 11177, 11178, 11184, 11185, 11188, 11188, 

11189, 11191, 11192, 11193, 11195, 11204