UNITED STATES OF AMERICA

DEPARTMENT OF TRANSPORTATION

FEDERAL AVIATION ADMINISTRATION

WASHINGTON, DC

IN THE MATTER OF THE PETITION FOR EXEMPTION OF:

ANDREW L. CHROSTOWSKI

FOR AN EXEMPTION SEEKING RELIEF FROM THE REQUIREMENTS OF TITLE 

14 OF THE CODE OF FEDERAL REGULATIONS SECTIONS 61.113(A) & (B), 91.7(A), 

91.121, 91.151(B), 91.405(A), 91.407(A)(1), 91.409(A)(1) & (A)(2), AND 91.417(A) & (B) 

CONCERNING COMMERCIAL OPERATION OF THE DJI INSPIRE 1 UNMANNED 

AIRCRAFT SYSTEM PURSUANT TO SECTION 333 OF THE FAA MODERNIZATION 

AND REFORM ACT OF 2012 (PUBLIC LAW 112-95)

SUBMITTED ON 

January 10, 2015

ANDREW L. CHROSTOWSKI

1409 WEST 29TH STREET

ERIE, PA 16508

(814) 882-7665

TABLE OF CONTENTS
1

GLOSSARY OF 

ABBREVIATIONS..................................................................................................2

SUMMARY...................................................................................................3

INTRODUCTION AND INTERESTS OF PETITIONER..........................................3

BACKGROUND.............................................................................................4

BASIS FOR PETITION....................................................................................4

NAME AND ADDRESS OF PETITIONER...................................................7

THE SPECIFIC SECTIONS OF 14 C.F.R. FROM WHICH ANDREW L. 

CHROSTOWSKI SEEKS EXEMPTION...............................................................7

THE EXTENT OF RELIEF ANDREW L. CHROSTOWSKI SEEKS AND THE 

REASON ANDREW L. CHROSTOWSKI SEEKS THE RELIEF..............................11

THE REASONS WHY GRANTING ANDREW L. CHROSTOWSKI’S REQUEST 

WOULD BE IN THE PUBLIC INTEREST...........................................................15

THE REASONS WHY GRANTING THE EXEMPTION WOULD NOT 

ADVERSELY AFFECT SAFETY......................................................................19

CONCLUSION.............................................................................................31

GLOSSARY OF ABBREVIATIONS

AGL ABOVE GROUND LEVEL

AOI AREA OF INTEREST

ATC AIR TRAFFIC CONTROL
2

ATO AIR TRAFFIC ORGANIZATION

AV AERIAL VEHICLE

CFR CODE OF FEDERAL REGULATIONS

COA CERTIFICATE OF AUTHORIZATION

FAA FEDERAL AVIATION ADMINISTRATION

FAR FEDERAL AVIATION REGULATION

GCS GROUND CONTROL STATION

GPS GLOBAL POSITIONING SYSTEM

LOL LOSS OF LINK

NAS NATIONAL AIRSPACE SYSTEM

NOTAM NOTICE TO AIRMAN

PIC PILOT IN COMMAND

SECTION 333 FAA MODERNIZATION AND REFORM ACT OF 2012 (FMRA)

SO SAFETY OBSERVER

SOP STANDARD OPERATING PROCEDURES

UA UNMANNED AIRCRAFT

UAS UNMANNED AIRCRAFT SYSTEM

VFR VISUAL FLIGHT RULES

VLOS VISUAL LINE OF SITE

VMC VISUAL METEOROLOGICAL CONDITIONS

VTOL VERTICAL TAKE OFF AND LANDING

DJI UAV MANUFACTURER

ESC ELECTRONIC SPEED CONTROL

FPV FIRST PERSON VIEW

LI-PO LITHIUM POLYMER BATTERY

RCV RADIO CONTROLLED VEHICLE

SUMMARY

ANDREW L. CHROSTOWSKI, OPERATING UNDER THE COMPANY TITLE, ELITE 

A/V SOLUTIONS SEEKS EXEMPTION FROM THE REQUIREMENTS OF 14 C.F.R 

61.113(A) & (B), 91.7(A), 91.121, 91.151(B), 91.405(A), 91.407(A)(1), 91.409(A)(1) & (A)(2), 

AND 91.417(A) & (B), TO OPERATE AN UNMANNED AIRCRAFT SYSTEM 

PURSUANT TO SECTION 333 OF THE FAA MODERNIZATION AND REFORM ACT 

OF 2012 (FMRA). THIS EXEMPTION WILL PERMIT ANDREW L. CHROSTOWSKI 

TO OPERATE AN UNMANNED AIRCRAFT SYSTEM (UAS) FOR THE 
3

COMMERCIAL PURPOSE OF CONDUCTING AERIAL VIDEO AND 

PHOTOGRAPHY FOR MARKETING, FILM SETS, REAL ESTATE PHOTOGRAPHY, 

COMMERCIALS, SPECIAL EVENTS, WEDDING CINEMATOGRAPHY, MARINE 

PHOTOGRAPHY AND VIDEOGRAPHY, ROOFING INSPECTION, AND 

LANDSCAPE IMAGING OVER CERTAIN AREAS OF THE UNITED STATES.

INTRODUCTION AND INTERESTS OF THE PETITIONER

MY NAME IS ANDREW L. CHROSTOWSKI, AND I AM AN AERIAL RCV 

ENTHUSIAST WITH OVER 5 YEARS OF EXPERIENCE OPERATING VARIOUS 

TYPES OF AERIAL RCV’S AS WELL AS 1 YEAR OPERATING QUADCOPTER 

UAS’S. ANDREW L. CHROSTOWSKI ALSO PROVIDES CUSTOMERS HIGH 

QUALITY PHOTOGRAPHY AND VIDEOGRAPHY FOR A WIDE RANGE OF 

APPLICATIONS. ANDREW L. CHROSTOWSKI IS CONSIDERED AN ADVANCED 

LEVEL RCV PILOT, WHO HAS EVEN TAUGHT BEGINNERS HOW TO PILOT 

RCV’S. 

THE OBJECTIVE OF ELITE A/V SOLUTIONS IS TO PROVIDE SUPERIOR 

AERIAL IMAGING FOR A WIDE RANGE OF INDUSTRIES AND EVENTS WHILE 

PROMOTING SAFE UAS OPERATIONS AND PROMOTING PUBLIC KNOWLEDGE 

OF UAS’S AS WELL AS PROVIDING A HIGH LEVEL OF KNOWLEDGE ABOUT 

UAS’S. 

BACKGROUND

UNMANNED AIRCRAFT SYSTEMS: DJI INSPIRE 1 UAS

ANDREW L. CHROSTOWSKI SEEKS AN EXEMPTION TO OPERATE THE 

DJI SYSTEM FOR COMPENSATION OR HIRE WITHIN THE NAS. THE DJI 

INSPIRE 1 IS A VERTICAL TAKEOFF AND LANDING (VTOL) UNMANNED 

AIRCRAFT (UA) WITH A GROUND CONTROL STATION (GCS) UTILIZING 

ELECTRONIC TABLET OR SMART PHONE SYSTEMS. THE DJI INSPIRE 1 HAS A 

MAXIMUM GROSS WEIGHT OF APPROXIMATELY 6 POUNDS 4 OUNCES, WHILE 

HAVING A LENGTH OF APPROXIMATELY 17 INCHES, WIDTH OF 17 INCHES, 

HEIGHT OF 11 INCHES, AND A MAXIMUM SPEED OF APPROXIMATELY 42 
4

KNOTS. THE DJI INSPIRE 1 IS EQUIPPED WITH FOUR MAIN ROTORS; DRIVEN 

BY A LITHIUM POLYMER BATTERY POWERED ELECTRIC MOTOR.

THE DJI INSPIRE 1 UAS THAT WILL BE OPERATED BY ANDREW L. 

CHROSTOWSKI WILL BE REGISTERED IN ACCORDANCE WITH 49 U.S.C. 44103, 

REGISTRATION OF AIRCRAFT, AS WELL AS 14 C.F.R. PART 47, AIRCRAFT 

REGISTRATION, AND MARKED IN ACCORDANCE WITH 14 C.F.R. PART 45, 

IDENTIFICATION AND REGISTRATION MARKINGS. 

BASIS FOR PETITION

PETITIONER, ANDREW L. CHROSTOWSKI, 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 C.F.R 61.113(A) & (B), 91.7(A), 

91.121, 91.151(B), 91.405(A), 91.407(A)(1), 91.409(A)(1) & (A)(2), AND 91.417(A) & (B).

IN CONSIDERATION OF THE SPEED, WEIGHT, SIZE, AND LIMITED 

OPERATING AREA ASSOCIATED WITH THE UNMANNED AIRCRAFT AND ITS 

OPERATION, ANDREW L. CHROSTOWSKI’S OPERATION OF THE 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, ANDREW L. CHROSTOWSKI REQUESTS RELIEF FROM 

SECTIONS 91.405(A), 91.407(A)(1), 91.409(A)(1) & (A)(2), AND 91.417(A) & (B), AS 

THESE SECTIONS SET FORTH REQUIREMENTS FOR MAINTENANCE THAT 

ONLY APPLY TO AIRCRAFT WITH AN AIRWORTHINESS CERTIFICATE. 

ANDREW L. CHROSTOWSKI SUBMITS THAT THE REQUESTED RELIEF IS 

PROPER SINCE AN EQUIVALENT LEVEL OF SAFETY WILL BE ENSURED. 

ANDREW L. CHROSTOWSKI WILL USE EXPERIENCED PERSONNEL OR 

TECHNICIANS TO PERFORM MAINTENANCE, ALTERATIONS, OR 

PREVENTATIVE MAINTENANCE ON THE UAS USING THE METHODS, 

TECHNIQUES, AND PRACTICES PRESCRIBED IN THE OPERATING DOCUMENTS 
5

(IE: MONTHLY MAINTENANCE LOG, AND DJI INSPIRE 1 MANUAL) 

FURTHERMORE, ANDREW L. CHROSTOWSKI WILL DOCUMENT AND 

MAINTAIN ALL MAINTENANCE RECORDS FOR THE DJI INSPIRE 1. 

RELIEF FROM CERTAIN REQUIREMENTS OF SECTION 61.113(A) AND (B), 

ENTITLED PRIVATE PILOT PRIVILEGES AND LIMITATIONS: PILOT IN 

COMMAND, IS REQUESTED BY ANDREW L. CHROSTOWSKI TO THE EXTENT 

NECESSARY TO ALLOW A PILOT IN COMMAND (PIC) HOLDING A PRIVATE 

PILOT OR HIGHER LEVEL CERTIFICATE, AS WELL AS AN AIRMAN MEDICAL 

CERTIFICATE, AND WHO HAS DEMONSTRATED, BY MEETING MINIMUM 

FLIGHT - HOUR AND CURRENCY REQUIREMENTS, THAT THE PIC IS ABLE TO 

SAFELY OPERATE THE DJI INSPIRE 1 UAS IN A MANNER CONSISTENT WITH 

THIS EXEMPTION, INCLUDING EVASIVE AND EMERGENCY MANEUVERS AND 

MAINTAINING APPROPRIATE DISTANCES FROM PEOPLE, VESSELS, VEHICLES, 

AND STRUCTURES. 

ANDREW L. CHROSTOWSKI SEEKS RELIEF FROM SECTION 91.7(A), 

ENTITLED CIVIL AIRCRAFT WORTHINESS, BECAUSE THE DJI INSPIRE 1 UAS 

DOES NOT REQUIRE AN AIRWORTHINESS CERTIFICATE IN ACCORDANCE 

WITH 14 C.F.R. PART 21, SUBPART H. AS SUCH, ANDREW L. CHROSTOWSKI 

SUBMITS THAT HE WILL ENSURE THAT THE DJI INSPIRE 1 UAS IS IN 

AIRWORTHY CONDITION PRIOR TO EVERY FLIGHT, BY DETERMINING THAT 

THE UAS IS IN COMPLIANCE WITH THE OPERATING DOCUMENTS (I.E., 

MONTHLY MAINTENANCE LOG, AND DJI INSPIRE 1 INSTRUCTION MANUAL), 

AND THAT THE AIRCRAFT IS IN A CONDITION FOR SAFE FLIGHT.

ANDREW L. CHROSTOWSKI ALSO SEEKS AN EXEMPTION FROM THE 

REQUIREMENTS OF SECTION 91.121, ENTITLED ALTIMETER SETTINGS, AS 

THE DJI INSPIRE 1 UAS WILL NOT HAVE A TYPICAL BAROMETRIC 

ALTIMETER ONBOARD. HOWEVER, ALTITUDE INFORMATION OF THE DJI 

INSPIRE 1 UAS WILL BE PROVIDED TO THE PIC VIA GLOBAL POSITIONING 
6

SYSTEM (GPS) EQUIPMENT AND RADIO COMMUNICATIONS TELEMETRY 

DATA LINK, WHICH DOWNLINKS FROM THE UAS TO THE GCS FOR ACTIVE 

MONITORING OF THE FLIGHT PATH. THIS ALTITUDE INFORMATION, 

COMBINED WITH ANDREW L. CHROSTOWSKI’S OPERATION OF THE DJI 

INSPIRE 1 UAS WITHIN VISUAL LINE OF SIGHT, AT OR BELOW 500 FEET AGL, 

WILL ENSURE A LEVEL OF SAFETY EQUIVALENT TO SECTION 91.121.

ADDITIONALLY, ANDREW L. CHROSTOWSKI SEEKS AN EXEMPTION 

FROM THE REQUIREMENTS OF SECTION 91.151(B), ENTITLED FUEL 

REQUIREMENTS FOR FLIGHT IN VFR CONDITIONS. ANDREW L. 

CHROSTOWSKI SUBMITS THAT SAFETY WILL NOT BE AFFECTED BY 

OPERATION OF THE 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 

APPROXIMATELY 18 MINUTES TO THE FIRST POINT OF INTENDED LANDING 

AND, ASSUMING NORMAL CRUISING SPEED, TO FLY AFTER THAT FOR AT 

LEAST 4.5 MINUTES. 

IN ACCORDANCE WITH 14 C.F.R 11.81, ANDREW L. CHROSTOWSKI 

PROVIDES THE FOLLOWING INFORMATION IN SUPPORT OF ITS PETITION 

FOR EXEMPTION:

A. NAME AND ADDRESS OF THE PETITIONER.

THE NAME AND ADDRESS OF THE PETITIONER AND POINT OF 

CONTACT IS:

ANDREW L. CHROSTOWSKI

1409 WEST 29TH STREET

ERIE, PA 16508

(814) 882.7665

EMAIL: ELITEAVS814TV@GMAIL.COM

A. THE SPECIFIC SECTIONS OF 14 C.F.R. FROM WHICH ANDREW L. 

CHROSTOWSKI SEEKS EXEMPTION.

1. ANDREW L. CHROSTOWSKI SEEKS EXEMPTION FROM THE 

REQUIREMENTS OF SECTION 61.113(A) AND (B).

SECTION 61.113, ENTITLED PRIVATE PRIVILEGES AND LIMITATIONS: 

PILOT IN COMMAND, SUBSECTIONS (A) AND (B) PRESCRIBE THE 

FOLLOWING, IN RELEVANT PART:
7

A. NO PERSON WHO HOLDS A PRIVATE PILOT CERTIFICATE MAY 

ACT AS A PILOT IN COMMAND (PIC) OF AN AIRCRAFT THAT IS 

CARRYING PROPERTY OR PASSENGERS FOR COMPENSATION OR 

HIRE; NOR MAY THAT PERSON, FOR COMPENSATION OR HIRE, 

ACT AS PIC OF AN AIRCRAFT.

B. 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 IDENTICAL TO THAT 

BUSINESS OR EMPLOYMENT; AND (2) THE AIRCRAFT DOES NOT 

CARRY PASSENGERS OR PROPERTY FOR COMPENSATION OR 

HIRE.

 2. ANDREW L. CHROSTOWSKI SEEKS EXEMPTION FROM THE 

 REQUIREMENTS OF SECTION 91.7(A).

SECTION 91.7, ENTITLED CIVIL AIRCRAFT WORTHINESS, SUBSECTION 

(A), STATES THE FOLLOWING: (A) NO PERSON MAY OPERATE A CIVIL 

AIRCRAFT UNLESS IT IS IN AN AIRWORTHY CONDITION.

 3. ANDREW L. CHROSTOWSKI SEEKS EXEMPTION FROM THE

 REQUIREMENTS OF SECTION 91.121.

SECTION 91.121, ENTITLED ALTIMETER SETTINGS, SUBSECTION (A), 

STATES THE FOLLOWING, IN PART:

A. EACH PERSON OPERATING AN AIRCRAFT SHALL MAINTAIN THE 

CRUISING ALTITUDE OR FLIGHT LEVEL OF THAT AIRCRAFT, AS 

THE CASE MAY BE, BY REFERENCE TO AN ALTIMETER THAT IS 

SET, WHEN OPERATING -- BELOW 18,000 FEET MSL, TO--

THE CURRENT REPORTED ALTIMETER SETTING OF A STATION

ALONG THE ROUTE AND WITHIN 100 NAUTICAL MILES OF THE

AIRCRAFT;

IF THERE IS NO STATION WITHIN THE AREA PRESCRIBED IN

PARAGRAPH (A)(1)(I) OF THIS SECTION, THE CURRENT REPORTED 

ALTIMETER SETTING OF AN APPROPRIATE AVAILABLE STATION; 

OR;

IN THE CASE OF AN AIRCRAFT NOT EQUIPPED WITH A RADIO,

THE ELEVATION OF THE DEPARTURE AIRPORT OR AN 
8

APPROPRIATE ALTIMETER SETTING AVAILABLE BEFORE

DEPARTURE.

 4. ANDREW L. CHROSTOWSKI SEEKS EXEMPTION FROM THE

REQUIREMENTS OF SECTION 91.151(B)..

SECTION 91.151, ENTITLED FUEL REQUIREMENTS FOR FLIGHT IN VFR

CONDITIONS, SUBSECTION (B), STATES THE FOLLOWING:

(B) NO PERSON MAY BEGIN A FLIGHT IN A ROTORCRAFT UNDER 

VFR CONDITIONS UNLESS (CONSIDERING WIND AND ALL 

FORECAST WEATHER CONDITIONS) THERE IS ENOUGH FUEL

TO FLY TO THE FIRST POINT OF INTENDED LANDING AND, 

ASSUMING NORMAL CRUISING SPEED, TO FLY AFTER THAT 

FOR AT LEAST 20 MINUTES.

 5. ANDREW L. CHROSTOWSKI SEEKS EXEMPTION FROM THE

REQUIREMENTS OF SECTION 91.405(A).

SECTION 91.405, ENTITLED MAINTENANCE REQUIRED, SUBSECTION (A), 

STATES THE FOLLOWING: EACH OWNER OR OPERATOR OF AN

AIRCRAFT--

A. SHALL HAVE THAT AIRCRAFT INSPECTED AS PRESCRIBED IN 

SUBPART E OF THIS PART AND SHALL BETWEEN INSPECTIONS, 

EXCEPT AS PROVIDED IN PARAGRAPH (C) OF THIS SECTION, 

HAVE DISCREPANCIES REPAIRED AS PRESCRIBED IN PART 43 OF

THIS CHAPTER.

 6. ANDREW L. CHROSTOWSKI SEEKS EXEMPTION FROM THE

REQUIREMENTS OF SECTION 91.407(A)(1)

SECTION 91.407(A)(1), ENTITLED OPERATION AFTER MAINTENANCE, 

PREVENTIVE MAINTENANCE, REBUILDING, OR ALTERATION, 

SUBSECTION (A)(1), STATES THE FOLLOWING:

A. NO PERSON MAY OPERATE ANY AIRCRAFT THAT HAS 

UNDERGONE MAINTENANCE, PREVENTIVE MAINTENANCE,

REBUILDING, OR ALTERATION UNLESS-- (1) IT HAS BEEN 

APPROVED FOR RETURN TO SERVICE BY AN AUTHORIZED

PERSON UNDER 43.7 OF THIS CHAPTER.
9

 7. ANDREW L. CHROSTOWSKI SEEKS EXEMPTION FROM THE

REQUIREMENTS OF SECTIONS 91.409(A)(1) AND 91.409(A)(2).

SECTION 91.409, ENTITLED INSPECTIONS, SUBSECTION (A), STATES THE 

FOLLOWING:

A. EXCEPT AS PROVIDED IN PARAGRAPH (C) OF THIS SECTION, NO 

PERSON MAY OPERATE AN AIRCRAFT UNLESS, WITHIN THE 

PRECEDING 12 CALENDAR MONTHS, IT HAS HAD--

(1) AN ANNUAL INSPECTION IN ACCORDANCE WITH PART 43 OF THIS 

CHAPTER AND HAS BEEN APPROVED FOR RETURN TO SERVICE BY A 

PERSON AUTHORIZED BY 43.7 OF THIS CHAPTER, OR

(2) AN INSPECTION FOR THE ISSUANCE OF AN AIRWORTHINESS 

CERTIFICATE IN ACCORDANCE WITH PART 21 OF THIS CHAPTER.

 8. ANDREW L. CHROSTOWSKI SEEKS EXEMPTION FROM THE

REQUIREMENTS OF SECTIONS 91.417(A) AND 91.417(B).

SECTION 91.417, ENTITLED MAINTENANCE RECORDS, SUBSECTIONS (A)

AND (B), STATE THE FOLLOWING:

A. EXCEPT FOR WORK PERFORMED IN ACCORDANCE WITH 91.411 

AND 91.413, EACH REGISTERED OWNER OR OPERATOR SHALL 

KEEP THE FOLLOWING RECORDS FOR THE PERIODS SPECIFIED 

IN PARAGRAPH (B) OF THIS SECTION:

1. RECORDS OF THE MAINTENANCE, PREVENTIVE 

MAINTENANCE, AND ALTERATION AND RECORDS OF THE 100-

HOUR, ANNUAL, PROGRESSIVE, AND OTHER REQUIRED OR 

APPROVED INSPECTIONS, AS APPROPRIATE, FOR EACH 

AIRCRAFT (INCLUDING THE AIRFRAME) AND EACH ENGINE, 

PROPELLER, ROTOR, AND APPLIANCE OF AN AIRCRAFT. THE 

RECORDS MUST INCLUDE--

(I) A DESCRIPTION (OR REFERENCE TO DATA ACCEPTABLE

TO THE ADMINISTRATOR) OF THE WORK

PERFORMED; AND

(II) THE DATE OF COMPLETION OF THE WORK PERFORMED

AND

(III) THE SIGNATURE, AND CERTIFICATE NUMBER OF THE 
10

PERSON APPROVING THE AIRCRAFT FOR RETURN TO 

SERVICE.

2. RECORDS CONTAINING THE FOLLOWING INFORMATION:

(I) THE TOTAL TIME IN SERVICE OF THE AIRFRAME, EACH

ENGINE, EACH PROPELLER, AND EACH ROTOR.

(II) THE CURRENT STATUS OF LIFE LIMITED PARTS OF 

EACH AIRFRAME, ENGINE, PROPELLER, ROTOR, AND 

APPLIANCE.

(III) THE TIME SINCE LAST OVERHAUL OF ALL ITEMS 

INSTALLED ON THE AIRCRAFT WHICH ARE REQUIRED TO 

BE OVERHAULED ON A SPECIFIED TIME BASIS.

(IV) THE CURRENT INSPECTION STATUS OF THE AIRCRAFT, 

INCLUDING THE TIME SINCE THE LAST INSPECTION

REQUIRED BY THE INSPECTION PROGRAM UNDER WHICH

THE AIRCRAFT AND ITS APPLIANCES ARE MAINTAINED.

(V) THE CURRENT STATUS OF APPLICABLE

AIRWORTHINESS DIRECTIVES (AD) 

AND SAFETY DIRECTIVES INCLUDING, FOR EACH, THE 

METHOD OF COMPLIANCE, THE AD OR SAFETY DIRECTIVE 

NUMBER AND REVISION DATE. IF THE AD OR SAFETY 

DIRECTIVE INVOLVES RECURRING ACTION, THE TIME AND 

DATE WHEN THE NEXT ACTION IS REQUIRED.

(VI) COPIES OF THE FORMS PRESCRIBED BY 43.9(D) OF THIS 

CHAPTER FOR EACH MAJOR ALTERATION TO THE 

AIRFRAME AND CURRENTLY INSTALLED ENGINES, 

ROTORS, PROPELLERS, AND APPLIANCES.

3. THE OWNER OR OPERATOR SHALL RETAIN THE FOLLOWING 

RECORDS FOR THE PERIODS PRESCRIBED:

(I) THE RECORDS SPECIFIED IN PARAGRAPH (A)(1) OF THIS 

SECTION SHALL BE RETAINED UNTIL THE WORK IS 

REPEATED OR SUPERSEDED BY OTHER WORK OR FOR 1 

YEAR AFTER WORK IS PERFORMED.

(II) THE RECORDS SPECIFIED IN PARAGRAPH (A)(2) OF THIS

SECTION SHALL BE RETAINED AND TRANSFERRED WITH 

THE AIRCRAFT AT THE TIME THE AIRCRAFT IS SOLD.

(III) A LIST OF DEFECTS FURNISHED TO A REGISTERED 

OWNER OR OPERATOR UNDER 43.11 OF THIS CHAPTER 
11

SHALL BE RETAINED UNTIL THE DEFECTS ARE REPAIRED 

AND THE AIRCRAFT IS APPROVED FOR RETURN TO 

SERVICE. 

B. THE EXTENT OF RELIEF ANDREW L. CHROSTOWSKI SEEKS AND THE 

REASON ANDREW L. CHROSTOWSKI SEEKS THE RELIEF.

1. EXTENT OF RELIEF ANDREW L. CHROSTOWSKI SEEKS AND THE 

REASON ANDREW L. CHROSTOWSKI SEEKS RELIEF FROM 

SECTION 61.113(A) AND (B).

RELIEF FROM SECTION 61.113(A) AND (B) ENTITLED 

PRIVATE PILOT PRIVILEGES AND LIMITATIONS: PILOT IN 

COMMAND, IS REQUESTED TO THE EXTENT NECESSARY TO 

ALLOW A PIC HOLDING A PRIVATE PILOT OR HIGHER LEVEL

CERTIFICATE, AS WELL AS CURRENT AND VALID AIRMAN 

MEDICAL CERTIFICATE, 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.

AS SET FORTH MORE FULLY BELOW, ANDREW L.

CHROSTOWSKI 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 IS ABLE TO SAFELY 

OPERATE 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.

FURTHERMORE, ANDREW L. CHROSTOWSKI SUBMITS 

THAT ALL FLIGHTS OF THE DJI INSPIRE 1 UAS, CONDUCTED BY THE PIC 

PURSUANT TO THE GRANT OF THIS PETITION: (1) WILL BE INCIDENTAL 

TO ANDREW L. CHROSTOWSKI’S BUSINESS; AND (2) WILL NOT CARRY 

PASSENGERS OR PROPERTY FOR COMPENSATION OR HIRE.
12

2. EXTENT OF RELIEF ANDREW L. CHROSTOWSKI SEEKS AND THE 

REASON ANDREW L. CHROSTOWSKI SEEKS RELIEF FROM 

SECTION 91.7(A).

RELIEF FROM SECTION 91.7(A) ENTITLED CIVIL AIRCRAFT 

WORTHINESS, IS REQUESTED TO THE EXTENT REQUIRED TO ALLOW 

ANDREW L. CHROSTOWSKI TO DETERMINE THAT THE DJI INSPIRE 1 

UAS IS IN AIRWORTHY CONDITION PRIOR TO EVERY FLIGHT BY 

ENSURING THAT THE UAS IS IN COMPLIANCE WITH THE OPERATING 

DOCUMENTS (I.E., ANDREW L. CHROSTOWSKI’S AERIAL OPERATIONS 

MANUAL, MONTHLY MAINTENANCE LOG, AND DJI INSPIRE 1 

INSTRUCTION MANUAL, PRE-FLIGHT CHECKLIST).

ANDREW L. CHROSTOWSKI 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, ANDREW L. CHROSTOWSKI WILL ENSURE 

THAT THE DJI INSPIRE 1 UAS IS IN AIRWORTHY CONDITION BASED 

UPON ITS COMPLIANCE WITH THE OPERATING DOCUMENTS (I.E., 

MONTHLY MAINTENANCE LOG, AND DJI INSPIRE 1 INSTRUCTION 

MANUAL) PRIOR TO EVERY FLIGHT, AND FURTHER, DETERMINE THAT 

THE AIRCRAFT IS IN CONDITION FOR SAFE FLIGHT, AS STATED IN THE 

CONDITIONS AND LIMITATIONS BELOW.

3. EXTENT OF RELIEF ANDREW L. CHROSTOWSKI SEEKS AND THE 

REASON ANDREW L. CHROSTOWSKI SEEKS RELIEF FROM 

SECTION 91.121.

RELIEF FROM SECTION 91.121, ENTITLED ALTIMETER SETTINGS, 

MAY BE REQUIRED TO ALLOW FLIGHT OPERATIONS OF THE DJI 

INSPIRE 1 UAS, WHICH UTILIZES A BAROMETRIC PRESSURE SENSOR, 

GPS EQUIPMENT, AND A RADIO COMMUNICATIONS TELEMETRY DATA 

LINK TO DOWNLINK ALTITUDE INFORMATION FROM THE UA 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), ANDREW L. CHROSTOWSKI 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.
13

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 IS 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. 

4. EXTENT OF RELIEF ANDREW L. CHROSTOWSKI SEEKS AND THE

REASON ANDREW L. CHROSTOWSKI SEEKS RELIEF FROM

SECTION 91.151(B).

RELIEF FROM SECTION 91.151(B) 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 15.5 MINUTES TO THE FIRST POINT 

OF INTENDED LANDING AND, ASSUMING NORMAL CRUISING SPEED, TO 

FLY AFTER THAT FOR AT LEAST 4.5 MINUTES. ANDREW L. 

CHROSTOWSKI SEEKS THE REQUESTED RELIEF BECAUSE WITHOUT AN 

EXEMPTION FROM SECTION 91.151(B), 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 ANDREW L. CHROSTOWSKI 

PROPOSES TO CONDUCT PURSUANT TO THIS PETITION. 

SIGNIFICANTLY, AS SET FORTH BELOW, THE TECHNICAL 

SPECIFICATIONS OF THE DJI INSPIRE 1 UAS, THE DJI INSPIRE 1 UAS’S 

OPERATING DOCUMENTS, AND PROPOSED OPERATING LIMITATIONS, 

ENSURE THAT ANDREW L. CHROSTOWSKI 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 15.5 MINUTES TO THE FIRST POINT OF INTENDED 

LANDING AND, ASSUMING NORMAL CRUISING SPEED, TO FLY AFTER 

THAT FOR AT LEAST 4.5 MINUTES.

5. EXTENT OF RELIEF ANDREW L. CHROSTOWSKI SEEKS AND THE 
14

REASON ANDREW L. CHROSTOWSKI SEEKS RELIEF FROM 

SECTIONS 91.405(A), 91.407(A)(1), 91.409(A)(1) & (A)(2), AND 91.4417(A)

& (B). 

SINCE SECTIONS 91.405(A), 91.407(A)(1), 91.409(A)(1) & (A)(2),

AND 91.4417(A) & (B) ONLY APPLY TO AIRCRAFT WITH AN 

AIRWORTHINESS CERTIFICATE, ANDREW L. CHROSTOWSKI REQUESTS 

RELIEF FROM THESE SECTIONS BECAUSE THE DJI INSPIRE 1 UAS DOES 

NOT REQUIRE AIRWORTHINESS CERTIFICATES. AS SET FORTH MORE 

FULLY BELOW, THE DJI INSPIRE 1 UAS MEETS THE CONDITIONS OF 

FMRA SECTION 333 FOR OPERATION WITHOUT AN AIRWORTHINESS 

CERTIFICATE. ACCORDINGLY, ANDREW L. CHROSTOWSKI WILL USE 

TRAINED TECHNICIANS TO PERFORM MAINTENANCE, ALTERATIONS, 

OR PREVENTIVE MAINTENANCE ON THE UAS USING THE METHODS, 

TECHNIQUES, AND PRACTICES PRESCRIBED IN THE UAS OPERATING 

DOCUMENTS (I.E., ANDREW L. CHROSTOWSKI AERIAL OPERATIONS 

MANUAL, MONTHLY MAINTENANCE LOG, DJI INSPIRE 1 INSTRUCTION 

MANUAL, PRE-FLIGHT CHECKLIST). FURTHERMORE, ANDREW L. 

CHROSTOWSKI WILL DOCUMENT AND MAINTAIN ALL MAINTENANCE 

RECORDS FOR THE DJI INSPIRE 1 UAS. 

C. THE REASONS WHY GRANTING ANDREW L. CHROSTOWSKI’S REQUEST 

WOULD BE IN THE PUBLIC INTEREST; THAT IS, HOW IT WOULD 

BENEFIT THE PUBLIC AS A WHOLE.

GRANTING THE PRESENT PETITION WILL FURTHER THE PUBLIC 

INTEREST BY ALLOWING ANDREW L. CHROSTOWSKI TO SAFELY, 

EFFICIENTLY, AND ECONOMICALLY PERFORM AERIAL VIDEO AND 

PHOTOGRAPHY OF CONSTRUCTION SITES, REAL ESTATE, AND 

LANDSCAPE, BOATS, EVENTS, ECT. OVER CERTAIN AREAS OF THE 

UNITED STATES.

ADDITIONALLY, USE OF THE DJI INSPIRE 1 UAS WILL DECREASE 

CONGESTION OF THE NAS, REDUCE POLLUTION, CRASHES AND 

ACCIDENTS CAUSED BY PILOT ERROR AND PROVIDE SIGNIFICANT 

BENEFITS TO THE ECONOMY. NOTABLY, THE BENEFITS OF ANDREW L. 

CHROSTOWSKI’S PROPOSED OPERATION OF THE DJI INSPIRE 1 UAS 

WILL BE REALIZED WITHOUT IMPLICATING ANY PRIVACY ISSUES.

1. THE PUBLIC WILL BENEFIT FROM DECREASED 

CONGESTION OF THE NAS.
15

THE DJI INSPIRE 1 UAS IS BATTERY POWERED AND 

SERVES AS A SAFE, EFFICIENT, AND ECONOMICAL 

ALTERNATIVE TO THE MANNED AIRCRAFT 

TRADITIONALLY UTILIZED TO OBTAIN AERIAL IMAGERY. 

BY REDUCING THE AMOUNT OF MANNED AIRCRAFT 

NEEDED TO PERFORM AERIAL ACQUISITIONS, AN 

EXEMPTION ALLOWING THE USE OF A DJI INSPIRE 1 UAS 

WOULD REDUCE THE AMOUNT OF MANNED AIRCRAFT IN

THE NAS, REDUCE NOISE AND AIR POLLUTION, AS WELL AS 

INCREASE THE SAFETY OF LIFE AND PROPERTY IN THE AIR

AND ON THE GROUND.

FURTHERMORE, BY REDUCING THE NUMBER OF

MANNED AIRCRAFT OPERATING IN THE NAS, CONGESTION

AROUND AIRPORTS CAUSED BY ARRIVING AND DEPARTING 

AIRCRAFT WILL BE REDUCED. THE DJI INSPIRE 1 DOES 

NOT REQUIRE AN AIRPORT TO TAKEOFF OR LAND. 

LIKEWISE, A REDUCTION OF MANNED AIRCRAFT 

CONDUCTING AERIAL VIDEO AND PHOTOGRAPHY

MISSIONS WOULD RESULT IN FEWER AIRCRAFT THAT 

MUST BE HANDLED BY AIR TRAFFIC CONTROL DURING 

THE GROUND, TAKEOFF, DEPARTURE, ARRIVAL, AND

LANDING PHASES OF FLIGHT OPERATIONS.

2. THE PUBLIC WILL BENEFIT FROM THE SAFETY AND 

EFFICIENCY OF THE DJI INSPIRE 1 UAS.

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 CABIN CLASS, SIX CYLINDER 

INTERNAL COMBUSTION ENGINE AIRCRAFT THAT ARE 

TYPICALLY UTILIZED FOR AERIAL VIDEO AND 

PHOTOGRAPHY, WHILE BURNING APPROXIMATELY 20-30 

GALLONS PER HOUR OF LEADED AVIATION FUEL. THE 
16

DJI INSPIRE 1 UAS, WHILE REDUCING THE CARBON 

FOOTPRINT OF AERIAL ACQUISITIONS, ALSO ELIMINATES

NOISE POLLUTION, AS THE UAS IS PROPELLED BY 

BATTERY POWERED ELECTRIC MOTORS, RATHER THAN 

AN INTERNAL COMBUSTION ENGINE.

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. ASIDE FROM

THE LACK OF FLIGHT CREW MEMBERS LOCATED 

ONBOARD THE AIRCRAFT, THE DJI INSPIRE 1 (WEIGHING 

APPROXIMATELY 6 POUNDS 4 OUNCES AT ITS MAXIMUM

GROSS WEIGHT, WITH A LENGTH OF APPROXIMATELY 17 

INCHES, WIDTH OF 17 INCHES, HEIGHT OF 11 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 (WEIGHING APPROXIMATELY 6,000 

POUNDS WITH A WINGSPAN OF APPROXIMATELY 42 FEET, 

A LENGTH OF 34 FEET, AND FUEL CAPACITY OF 180 

GALLONS).

3. PERFORMING AERIAL VIDEO AND PHOTOGRAPHY OPERATIONS 

WITH THE DJI INSPIRE 1 UAS WILL BENEFIT THE ECONOMY.

IN ADDITION TO BEING SAFE AND EFFICIENT, THE DJI

INSPIRE 1 UAS IS ALSO AN ECONOMICAL ALTERNATIVE TO USING 

MANNED AIRCRAFT TO CONDUCT SIMILAR AERIAL OPERATIONS. 

AS SUCH, OPERATION OF THE DJI INSPIRE 1 UAS WILL ALLOW 

UNITED STATES BASED COMPANIES, LIKE ELITE A/V SOLUTIONS, 

TO REMAIN COMPETITIVE AND CONTRIBUTE TO THE GROWTH 

OF THE U.S. ECONOMY. SPECIFICALLY, WITH THE RISING COST 

OF AVIATION FUEL AND THE ENVIRONMENTAL PROTECTION 

AGENCY (“EPA”) REGULATORY ACTIONS PHASING OUT LEADED 

AVIATION FUELS, U.S. OWNED AND OPERATED COMPANIES MUST 

ADOPT NEW AND ALTERNATIVE TECHNOLOGY IN ORDER TO 

REMAIN COMPETITIVE. OPERATING THE BATTERY POWERED 
17

DJI INSPIRE 1 UAS IS ONE SUCH TECHNOLOGY THAT NOT ONLY 

ALLOWS COMPANIES GREATER OPERATIONAL FLEXIBILITY 

COMPARED TO MANNED AIRCRAFT, BUT PROVIDES SUCH 

FLEXIBILITY WITHOUT THE HIGH OPERATIONAL COST OF A 

TRADITIONAL MANNED AIRCRAFT.

BY OPERATING THE DJI INSPIRE 1 UAS, COMPANIES SUCH 

AS ELITE A/V SOLUTIONS, CAN REMAIN COMPETITIVE AND 

PROFITABLE, AND THEREFORE, PROVIDE GREATER JOB 

STABILITY TO EMPLOYEES AND CONTRACTORS, WHICH WILL 

ULTIMATELY CONTRIBUTE TO GROWTH OF THE U.S. ECONOMY. 

IMPROVED FINANCIAL PERFORMANCE OF U.S. COMPANIES, 

THROUGH COMMERCIAL USE OF THE DJI INSPIRE 1 UAS, 

PROVIDES A STABLE WORKFORCE THAT INCREASES CONSUMER 

SPENDING; IMPROVES LOCAL, STATE, AND FEDERAL TAX 

REVENUES; AND ALLOWS COMPANIES TO INVEST IN RESEARCH 

AND DEVELOPMENT IN ORDER TO REMAIN COMPETITIVE BOTH 

IN THE UNITED STATES AND ABROAD.

4. THERE ARE NO PRIVACY ISSUES.

SIMILAR TO THE MANNED AERIAL ACQUISITION FLIGHT 

OPERATIONS THAT HAVE BEEN CONDUCTED FOR DECADES,

ANDREW L. CHROSTOWSKI’S PROPOSED OPERATION OF THE DJI 

INSPIRE 1 UAS WILL NOT IMPLICATE ANY PRIVACY ISSUES. 

SPECIFICALLY, THE DJI INSPIRE 1 UAS WILL BE OPERATED ONLY 

IN COMPLIANCE WITH OPERATING DOCUMENTS (I.E., ANDREW L. 

CHROSTOWSKI AERIAL OPERATIONS MANUAL, MONTHLY 

MAINTENANCE LOG, DJI INSPIRE 1 AND INSTRUCTION MANUAL, 

PRE-FLIGHT CHECKLIST) WHICH REQUIRES PROPERTY OWNER 

INVOLVEMENT AS WELL AS LOCAL LAW ENFORCEMENT 

NOTIFICATION, AND IN ACCORDANCE WITH THE FEDERAL 

AVIATION REGULATIONS, INCLUDING THE MINIMUM ALTITUDE 

REQUIREMENTS OF 14 C.F.R. 91.119. 

 

E. THE REASONS WHY GRANTING THE EXEMPTION WOULD NOT

ADVERSELY AFFECT SAFETY, OR HOW THE EXEMPTION WOULD
18

PROVIDE A LEVEL OF SAFETY AT LEAST EQUAL TO THAT PROVIDED

BY THE RULE FROM WHICH ANDREW L. CHROSTOWSKI SEEKS

EXEMPTION. 

1. REASONS WHY THE DJI INSPIRE 1 UAS MEETS THE CONDITIONS

OF THE FAA MODERNIZATION AND REFORM ACT OF 2012 (FMRA)

SECTION 333.

IN CONSIDERATION OF THE SIZE, WEIGHT, SPEED, AND LIMITED 

OPERATING AREA ASSOCIATED WITH THE UNMANNED AIRCRAFT AND 

ITS OPERATION, ANDREW L. CHROSTOWSKI’S OPERATION OF THE DJI 

INSPIRE 1 UAS MEETS THE CONDITIONS OF FMRA SECTION 333, AND 

WILL NOT REQUIRE AN AIRWORTHINESS CERTIFICATE IN 

ACCORDANCE WITH 14 C.F.R. PART 21, SUBPART H. SECTION 333 

PROVIDES AUTHORITY FOR A UAS TO OPERATE WITHOUT 

AIRWORTHINESS CERTIFICATION AND SETS FORTH REQUIREMENTS 

FOR CONSIDERING WHETHER A UAS WILL CREATE A HAZARD TO 

USERS OF THE NAS OR THE PUBLIC, OR OTHERWISE POSE A THREAT 

TO NATIONAL SECURITY. SPECIFICALLY, FMRA SECTION 333 STATES 

THE FOLLOWING, IN PART:

(A)IN GENERAL -- NOTWITHSTANDING ANY OTHER 

REQUIREMENT OF THIS SUBTITLE, AND NOT LATER THAN 

180 DAYS AFTER THE DATE OF ENACTMENT OF THIS ACT, 

THE SECRETARY OF TRANSPORTATION SHALL DETERMINE 

IF CERTAIN UNMANNED AIRCRAFT SYSTEMS MAY 

OPERATE SAFELY IN THE NATIONAL AIRSPACE SYSTEM 

BEFORE COMPLETION OF THE PLAN AND RULEMAKING 

REQUIRED BY SECTION 332 OF THIS ACT OR THE GUIDANCE 

REQUIRED BY SECTION 334 OF THIS ACT.

(B) ASSESSMENT OF UNMANNED AIRCRAFT SYSTEMS -- IN 

MAKING THE DETERMINATION UNDER SUBSECTION (A), 

THE SECRETARY SHALL DETERMINE, AT A MINIMUM --

1) WHICH TYPES OF UNMANNED AIRCRAFT SYSTEMS, IF 

ANY, AS A RESULT OF THEIR SIZE, WEIGHT, SPEED, 

OPERATIONAL CAPABILITY, PROXIMITY TO 

AIRPORTS AND POPULATED AREAS, AND OPERATION 

WITHIN VISUAL LINE OF SIGHT DO NOT CREATE A 

HAZARD TO USERS OF THE NATIONAL AIRSPACE 

SYSTEM OR THE PUBLIC OR POSE A THREAT TO 

NATIONAL SECURITY; AND WHETHER A 
19

CERTIFICATE OF WAIVER, CERTIFICATE OF 

AUTHORIZATION, OR AIRWORTHINESS 

CERTIFICATION UNDER SECTION 44704 OF TITLE 49, 

UNITED STATES CODE, IS REQUIRED FOR THE 

OPERATION OF UNMANNED AIRCRAFT SYSTEMS 

IDENTIFIED UNDER PARAGRAPH (1).

(C) REQUIREMENTS FOR SAFE OPERATION-- IF THE

 SECRETARY DETERMINES UNDER THIS SECTION THAT

 CERTAIN UNMANNED AIRCRAFT SYSTEMS MAY

 OPERATE SAFELY IN THE NATIONAL AIRSPACE

 SYSTEM, THE SECRETARY SHALL ESTABLISH

 REQUIREMENTS FOR THE SAFE OPERATION OF SUCH

 AIRCRAFT SYSTEMS IN THE NATIONAL AIRSPACE

 SYSTEM.

IN SEEKING THIS EXEMPTION, ANDREW L. 

CHROSTOWSKI SUBMITS THAT THE DJI INSPIRE 1 UAS CAN 

OPERATE SAFELY IN THE NAS PURSUANT TO FMRA 

SECTION 333, AS DEMONSTRATED BY: (A) THE 

CHARACTERISTICS OF THE DJI INSPIRE 1 UAS; (B) THE 

PILOT CERTIFICATION REQUIREMENT; AND (C) THE 

SPECIFIC OPERATING LIMITATIONS.

A. THE SPECIFICATIONS OF THE DJI INSPIRE 1 UAS 

DEMONSTRATES 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.

I. TECHNICAL SPECIFICATIONS OF THE DJI INSPIRE 1 

UAS.

THE TECHNICAL SPECIFICATIONS OF THE DJI

INSPIRE 1 UAS IS SET FORTH BY THE DJI 

INSPIRE 1 SPECIFICATIONS AND DATA SHEET,

ATTACHED HERETO AS EXHIBIT A.

II. THE DJI INSPIRE 1 UAS’ AUTONOMOUS FLIGHT AND

NAVIGATION MODES ENABLE THE UAS TO REMAIN

WITHIN A DEFINED OPERATIONAL AREA.

THE DJI INSPIRE 1 UAS MAY BE OPERATED IN 

BOTH MANUAL AND FULLY AUTONOMOUS 
20

FLIGHT MODES. A COMPLETE DESCRIPTION 

OF THE FLIGHT AND NAVIGATIONAL MODES 

OF THE DJI INSPIRE 1 UAS IS PROVIDED AT 

PAGES 12, 44-51 OF THE DJI INSPIRE 1 USER 

MANUAL, ATTACHED HERETO AS EXHIBIT B.

III. THE DJI INSPIRE 1 UAS IS DESIGNED FOR AUTOMATIC

RETURN TO HOME POINT OR HOVER IN THE EVENT

OF LOSS OF THE CONTROL LINK OR NAVIGATION.

WHEN THE CONTROL LINK 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

GCS, THE UAS WILL ASSUME THAT THE

CONTROL LINK IS LOST AND THE UAS WILL

RETURN TO THE HOME POSITION AND

SHUTDOWN. A COMPLETE DESCRIPTION OF

THE FAILSAFE FUNCTIONS OF THE DJI INSPIRE

1 UAS ARE SET FORTH AT PAGE 60 OF THE DJI

INSPIRE 1 USER MANUAL, ATTACHED HERETO 

AS EXHIBIT B.

IV. THE DJI INSPIRE 1 GCS AND ITS OPERATION.

A COMPLETE DESCRIPTION OF THE

OPERATION AND SPECIFICATIONS OF THE 

DJI INSPIRE 1 GCS AND FLIGHT CONTROL 

SOFTWARE IS PROVIDED AT PAGES 57 TO 62 OF

THE DJI INSPIRE 1 USER MANUAL. DJI INSPIRE

1 USER MANUAL IS ATTACHED HERETO AS

EXHIBIT B.

B. FLIGHT OPERATIONS OF DJI INSPIRE 1 UAS IS LIMITED TO THE

LINE OF SIGHT OF A CERTIFIED PILOT IN COMMAND WITH A

SAFETY OBSERVER.

ANDREW L. CHROSTOWSKI WILL ONLY UTILIZE 

CERTIFICATED PILOTS WHO POSSESS A CURRENT AND VALID 

AIRMAN MEDICAL CERTIFICATE TO ACT AS A PILOT IN 

COMMAND (PIC) OF THE DJI INSPIRE 1 UAS. ADDITIONALLY, A 
21

SAFETY OBSERVER WILL ASSIST ALL PILOTS DURING FLIGHT 

TIME.

C. FLIGHTS OF DJI INSPIRE 1 UAS WILL BE CONDUCTED PURSUANT

TO SPECIFIC OPERATING LIMITATIONS.

IN SEEKING THIS EXEMPTION, ANDREW L. CHROSTOWSKI 

PROPOSES TO COMMERCIALLY OPERATE THE DJI INSPIRE 1 UAS 

FOR THE SPECIAL PURPOSE OF CONDUCTING AERIAL VIDEO AND

PHOTOGRAPHY OVER CERTAIN AREAS OF THE UNITED STATES, 

PURSUANT TO THE FOLLOWING SPECIFIC OPERATING 

LIMITATIONS:

1. OPERATIONS AUTHORIZED BY THIS GRANT OF EXEMPTION 

WILL BE LIMITED TO THE FOLLOWING AIRCRAFT DESCRIBED IN 

THE OPERATING DOCUMENTS, ROTORCRAFT UAS’ WEIGHING 

LESS THAN 55 POUNDS MAXIMUM GROSS WEIGHT: DJI INSPIRE 1 

UNMANNED AIRCRAFT SYSTEM. PROPOSED OPERATIONS OF ANY 

OTHER AIRCRAFT WILL REQUIRE A NEW PETITION OR A 

PETITION TO AMEND THIS GRANT.

2. UAS OPERATIONS UNDER THIS EXEMPTION WILL BE LIMITED 

TO CONDUCTING OPERATIONS FOR THE PURPOSE OF AERIAL 

VIDEO AND PHOTOGRAPHY.

3. THE UAS MAY NOT BE FLOWN AT AN INDICATED AIRSPEED 

EXCEEDING 20 KNOTS.

4. THE UAS MUST BE OPERATED AT AN ALTITUDE OF NO MORE 

THAN 500 FEET ABOVE GROUND LEVEL (AGL), AS INDICATED BY 

THE PROCEDURES SPECIFIED IN THE OPERATING DOCUMENTS 

UNLESS A SPECIAL REQUEST IS MADE AND APPROVED BY THE 

ATC. ALL ALTITUDES REPORTED TO ATC MUST BE IN FEET AGL.

5. THE UAS MUST BE OPERATED WITHIN VISUAL LINE OF SIGHT 

(VLOS) OF THE PIC AT ALL TIMES. THIS REQUIRES THE PIC TO 

BE ABLE TO USE HUMAN VISION UNAIDED BY ANY DEVICE 

OTHER THAN CORRECTIVE LENSES, AS SPECIFIED ON THE PIC’S 

FAA-ISSUED AIRMAN MEDICAL CERTIFICATE.
22

6. THE USE OF FIRST PERSON VIEW (FPV) BY THE PIC OR SAFETY 

OBSERVER (SO) IS NOT PERMITTED.

7. ALL OPERATIONS MUST UTILIZE A SAFETY OBSERVER (SO). 

THE SO MAY BE USED TO SATISFY THE VLOS REQUIREMENT AS 

LONG AS THE PIC ALWAYS MAINTAINS VLOS CAPABILITY. THE 

SO 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 SO CAN PERFORM THE FUNCTIONS 

PRESCRIBED IN THE OPERATING DOCUMENTS. 

8. THE SO MUST NOT PERFORM ANY OTHER DUTIES BEYOND 

ASSISTING THE PIC WITH SEEING AND AVOIDING OTHER AIR 

TRAFFIC AND OTHER GROUND BASED 

OBSTACLES/OBSTRUCTIONS AND IS NOT PERMITTED TO 

OPERATE THE CAMERA OR OTHER INSTRUMENTS.

9. THE OPERATING DOCUMENTS AND THE GRANT OF EXEMPTION 

MUST BE ACCESSIBLE DURING UAS OPERATIONS AND MADE 

AVAILABLE TO THE ADMINISTRATOR UPON REQUEST. IF A 

DISCREPANCY EXISTS BETWEEN THE CONDITIONS AND 

LIMITATIONS CONTAINED IN THE GRANT OF EXEMPTION AND 

THE PROCEDURES OUTLINED IN THE OPERATING DOCUMENTS, 

THE CONDITIONS AND LIMITATIONS CONTAINED IN THE GRANT 

OF EXEMPTION 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 UPON REQUEST. THE OPERATOR MUST ALSO 

PRESENT UPDATED AND REVISED DOCUMENTS IF IT PETITIONS 

FOR EXTENSION OR AMENDMENT TO THE GRANT OF 

EXEMPTION. IF THE OPERATOR DETERMINES THAT ANY 

UPDATE OR REVISION WOULD AFFECT THE BASIS UPON WHICH 

THE FAA GRANTED THE EXEMPTION, THEN THE OPERATOR 

MUST PETITION FOR AMENDMENT TO ITS GRANT OF 

EXEMPTION. THE FAA’S UAS INTEGRATION OFFICE (AFS-80) MAY 
23

BE CONTACTED IF QUESTIONS ARISE REGARDING UPDATES OR 

REVISIONS TO THE OPERATING DOCUMENTS.

10. PRIOR TO EACH FLIGHT THE PIC MUST INSPECT THE UAS TO 

ENSURE THAT IT IS IN A CONDITION FOR SAFE FLIGHT. 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. THE GROUND CONTROL STATION MUST BE 

INCLUDED IN THE PREFLIGHT INSPECTION. ALL MAINTENANCE 

AND ALTERATIONS MUST BE PROPERLY DOCUMENTED IN THE 

AIRCRAFT RECORDS.

11. 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. 

THE PIC WHO CONDUCTS THE FUNCTIONAL TEST FLIGHT MUST 

MAKE AN ENTRY IN THE AIRCRAFT RECORDS. 

12. THE PRE-FLIGHT INSPECTION MUST ACCOUNT FOR ALL 

POTENTIAL DISCREPANCIES, E.G. INOPERABLE COMPONENTS, 

ITEMS, OR EQUIPMENT, NOT ALREADY COVERED IN THE 

RELEVANT SECTIONS OF THE OPERATING DOCUMENTS. 

13. THE OPERATOR MUST FOLLOW THE UAS MANUFACTURER’S 

AIRCRAFT/COMPONENT, MAINTENANCE, OVERHAUL, 

REPLACEMENT, INSPECTION, AND LIFE LIMIT REQUIREMENTS.

14. THE OPERATOR MUST CARRY OUT ITS MAINTENANCE, 

INSPECTIONS, AND RECORD KEEPING REQUIREMENTS, IN 

ACCORDANCE WITH THE OPERATING DOCUMENTS. 

MAINTENANCE, INSPECTION, ALTERATIONS, AND STATUS OF 

REPLACEMENT/OVERHAUL COMPONENT PARTS MUST BE NOTED 

IN THE AIRCRAFT RECORDS, INCLUDING TOTAL TIME IN 

SERVICE, DESCRIPTION OF WORK ACCOMPLISHED, AND THE 

SIGNATURE OF THE AUTHORIZED PERSON RETURNING THE UAS 

TO SERVICE.
24

15. EACH UAS OPERATED UNDER THIS EXEMPTION MUST 

COMPLY WITH ALL MANUFACTURER'S SAFETY BULLETINS.

16. THE AUTHORIZED PERSON MUST MAKE AN ENTRY IN THE 

AIRCRAFT RECORD OF THE CORRECTIVE ACTION TAKEN 

AGAINST DISCREPANCIES DISCOVERED BETWEEN INSPECTIONS.

17. THE PIC MUST POSSESS AT LEAST A PRIVATE PILOT 

CERTIFICATE AND AT LEAST A CURRENT THIRD-CLASS MEDICAL 

CERTIFICATE.

18. THE OPERATOR MAY NOT PERMIT ANY PIC TO OPERATE 

UNLESS THE PIC MEETS THE OPERATOR’S QUALIFICATION 

CRITERIA AND DEMONSTRATES THE ABILITY TO SAFELY 

OPERATE THE UAS IN A MANNER CONSISTENT WITH HOW THE 

UAS WILL BE OPERATED UNDER THE EXEMPTION, INCLUDING 

EVASIVE AND EMERGENCY MANEUVERS AND MAINTAINING 

APPROPRIATE DISTANCES FROM PERSONS, VESSELS, VEHICLES 

AND STRUCTURES. PIC QUALIFICATION FLIGHT HOURS MUST BE 

LOGGED IN A MANNER CONSISTENT WITH 14 C.F.R. 61.51(B). 

FLIGHTS FOR THE PURPOSES OF TRAINING THE OPERATOR’S 

PICS ARE PERMITTED UNDER THE TERMS OF THE 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 UAS WITH APPROPRIATE DISTANCE FROM 

NONPARTICIPANTS IN ACCORDANCE WITH 14 C.F.R. 91.119.

19. UAS OPERATIONS MAY NOT BE CONDUCTED DURING THE 

NIGHT, AS DEFINED IN 14 C.F.R. 1.1. ALL OPERATIONS MUST BE 

CONDUCTED UNDER VISUAL METEOROLOGICAL CONDITIONS 

(VMC). IF FLIGHT AT NIGHT IS REQUIRED, A SPECIAL REQUEST 

WILL BE MADE AT THE FAA OFFICE CLOSEST TO PROPOSED 

AREA OF OPERATIONS. FLIGHTS UNDER SPECIAL VISUAL 

FLIGHT RULES (SVFR) ARE NOT AUTHORIZED. 

20. THE UAS MAY NOT OPERATE WITHIN 5 NAUTICAL MILES OF 

AN AIRPORT REFERENCE POINT AS DENOTED ON A CURRENT 

FAA - PUBLISHED AERONAUTICAL CHART UNLESS A LETTER OF 
25

AGREEMENT WITH THAT AIRPORT’S MANAGEMENT IS 

OBTAINED, AND THE OPERATION IS CONDUCTED IN 

ACCORDANCE WITH A NOTAM AS REQUIRED BY THE 

OPERATOR’S COA. THE LETTER OF AGREEMENT WITH THE 

AIRPORT MANAGEMENT MUST BE MADE AVAILABLE TO THE 

ADMINISTRATOR UPON REQUEST.

21. THE UAS 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.

22. IF THE UAS LOSES COMMUNICATIONS OR LOSES ITS GPS 

SIGNAL, IT MUST RETURN TO A PREDETERMINED LOCATION 

WITHIN THE PLANNED OPERATING AREA AND LAND OR BE 

RECOVERED IN ACCORDANCE WITH THE OPERATING 

DOCUMENTS.

23. THE PIC MUST ABORT THE FLIGHT IN THE EVENT OF 

UNPREDICTED OBSTACLES OR EMERGENCIES IN ACCORDANCE 

WITH THE OPERATING DOCUMENTS.

24. THE PIC IS PROHIBITED FROM BEGINNING 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 LAND THE UAS WITH 

25% BATTERY POWER REMAINING.

25. THE OPERATOR MUST OBTAIN AN AIR TRAFFIC 

ORGANIZATION (ATO) ISSUED CERTIFICATE OF WAIVER OR 

AUTHORIZATION (COA) PRIOR TO CONDUCTING ANY 

OPERATIONS UNDER THE GRANT OF EXEMPTION. THIS COA 

WILL ALSO REQUIRE THE OPERATOR TO REQUEST A NOTICE TO 

AIRMAN (NOTAM) NOT MORE THAN 72 HOURS IN ADVANCE, BUT 

NOT LESS THAN 48 HOURS PRIOR TO THE OPERATION. ALL 

OPERATIONS SHALL BE CONDUCTED IN ACCORDANCE WITH 

AIRSPACE REQUIREMENTS IN THE ATO ISSUED COA INCLUDING 

CLASS OF AIRSPACE, ALTITUDE LEVEL, AND POTENTIAL 

TRANSPONDER REQUIREMENTS.
26

26. ALL AIRCRAFT OPERATED IN ACCORDANCE WITH THE 

EXEMPTION MUST BE IDENTIFIED BY SERIAL NUMBER, 

REGISTERED IN ACCORDANCE WITH 14 C.F.R. PART 47, AND HAVE 

IDENTIFICATION (N-NUMBER) MARKINGS IN ACCORDANCE WITH 

14 C.F.R. PART 45, SUBPART C. MARKINGS MUST BE AS LARGE AS 

PRACTICABLE.

27. BEFORE CONDUCTING OPERATIONS, THE RADIO FREQUENCY 

SPECTRUM USED FOR OPERATION AND CONTROL OF THE UA 

MUST COMPLY WITH THE FEDERAL COMMUNICATIONS 

COMMISSION (FCC) OR OTHER APPROPRIATE GOVERNMENT 

OVERSIGHT AGENCY REQUIREMENTS.

28. THE DOCUMENTS REQUIRED FEWER THAN 14 C.F.R. 91.9 AND 

91.203 MUST BE AVAILABLE TO THE PIC AT THE GROUND 

CONTROL STATION OF THE UAS ANY TIME THE UAS IS 

OPERATING. THESE DOCUMENTS MUST BE MADE AVAILABLE TO 

THE ADMINISTRATOR OR ANY LAW ENFORCEMENT OFFICIAL 

UPON REQUEST. 

29. THE UA MUST REMAIN CLEAR AND YIELD THE RIGHT OF WAY 

TO ALL MANNED AVIATION OPERATIONS AND ACTIVITIES AT 

ALL TIMES.

30. THE UAS MAY NOT BE OPERATED BY THE PIC FROM ANY 

MOVING DEVICE OR VEHICLE.

31. FLIGHT OPERATIONS MUST BE CONDUCTED AT LEAST 500 

FEET FROM ALL NONPARTICIPATING PERSONS (PERSONS OTHER 

THAN THE PIC, SO, OPERATOR TRAINEES OR ESSENTIAL 

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 AND/OR; 
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B. 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, AND;

C. OPERATIONS NEARER TO THE PIC, SO, OPERATOR 

TRAINEES OR ESSENTIAL PERSONS DO NOT PRESENT AN 

UNDUE HAZARD TO THOSE PERSONS PER 91.119(A).

32.ALL OPERATIONS SHALL BE CONDUCTED OVER PRIVATE OR

CONTROLLED-ACCESS PROPERTY WITH PERMISSION FROM THE 

LANDOWNER/CONTROLLER OR AUTHORIZED REPRESENTATIVE. 

PERMISSION FROM LAND OWNER/CONTROLLER OR 

AUTHORIZED REPRESENTATIVE WILL BE OBTAINED FOR EACH 

FLIGHT TO BE CONDUCTED.

33. 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.

2. REASONS WHY AN EXEMPTION FROM THE REQUIREMENTS OF

SECTION 61.113(A) AND (B) WOULD NOT ADVERSELY AFFECT SAFETY.

ANDREW L. CHROSTOWSKI SUBMITS THAT THE EQUIVALENT 

LEVEL OF SAFETY ESTABLISHED BY SECTION 61.113(A) AND (B) WILL BE 

MAINTAINED BECAUSE NO PIC WILL BE ALLOWED TO OPERATE THE 

DJI INSPIRE 1 UAS UNLESS THAT PIC HAS DEMONSTRATED, BY 

MEETING MINIMUM FLIGHT-HOUR AND CURRENCY REQUIREMENTS, 

THAT THE PIC IS ABLE TO SAFELY OPERATE THE DJI INSPIRE 1 UAS IN 

A MANNER CONSISTENT WITH THE EXEMPTION, INCLUDING EVASIVE 

AND EMERGENCY MANEUVERS AND MAINTAINING APPROPRIATE 

DISTANCES FROM PEOPLE, VESSELS, VEHICLES AND STRUCTURES.
28

CONSIDERING ANDREW L. CHROSTOWSKI’S PROPOSED AREA OF 

OPERATIONS, AND THE OPERATING LIMITATIONS SET FORTH-ABOVE; 

THE PARALLEL NATURE OF PRIVATE PILOT AERONAUTICAL 

KNOWLEDGE REQUIREMENTS TO THOSE OF COMMERCIAL PILOT 

REQUIREMENTS (SEE EXEMPTION NO. 11062); AND THE AIRMANSHIP 

SKILLS NECESSARY TO SAFELY OPERATE THE DJI INSPIRE 1 UAS, 

ANDREW L. CHROSTOWSKI SUBMITS THAT THE ADDITIONAL MANNED 

AIRMANSHIP EXPERIENCE OF A COMMERCIALLY CERTIFICATED 

PILOT WOULD NOT CORRELATE TO THE AIRMANSHIP SKILLS 

NECESSARY FOR ANDREW L. CHROSTOWSKI’S SPECIFIC PROPOSED 

FLIGHT OPERATIONS.

THE FAA HAS PREVIOUSLY GRANTED RELIEF FROM SECTION 

61.113 (A) AND (B) SPECIFIC TO UAS, IN CIRCUMSTANCES SIMILAR, IN 

ALL MATERIAL RESPECTS, TO THOSE PRESENTED HEREIN (E.G. 

EXEMPTION NOS. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 

11112, 11136, 11138, 11150, 11153, 11156, 11158, 11159, 11160, 11161). ANDREW 

L. CHROSTOWSKI WILL NOT ALLOW ANY PIC TO OPERATE THE DJI 

INSPIRE 1 UAS UNLESS THAT PIC HAS DEMONSTRATED, BY MEETING 

MINIMUM FLIGHT-HOUR REQUIREMENTS AND THE DJI INSPIRE 1 UAS 

TRAINING AND CURRENCY REQUIREMENTS, THAT THE PIC IS ABLE TO 

SAFELY OPERATE THE DJI INSPIRE 1 UAS IN A MANNER CONSISTENT 

WITH THIS EXEMPTION, INCLUDING EVASIVE AND EMERGENCY 

MANEUVERS AND MAINTAINING APPROPRIATE DISTANCES FROM 

PEOPLE, VESSELS, VEHICLES, AND STRUCTURES. SPECIFICALLY, THE 

PIC MUST HAVE ACCUMULATED AND LOGGED, IN A MANNER 

CONSISTENT WITH 14 C.F.R. 61.51(B), 25 HOURS OF TOTAL TIME AS A 

UAS ROTORCRAFT PILOT (WITH A MINIMUM OF 5 HOURS OF THOSE 

HOURS AS A UAS PILOT OPERATING THE SAME MAKE AND MODEL OF 

UAS TO BE USED FOR OPERATIONS UNDER THE EXEMPTION). IN 

ADDITION TO THE HOUR REQUIREMENTS, THE PIC MUST ACCOMPLISH 

3 TAKEOFFS AND LANDINGS IN THE PRECEDING 90 DAYS (FOR 

CURRENCY PURPOSES).

AS IN EXEMPTION NOS. 11062, 11138, AND 11153, PRIOR 

DOCUMENTED FLIGHT EXPERIENCE THAT WAS OBTAINED IN 

COMPLIANCE WITH APPLICABLE REGULATIONS WILL ENSURE AN 

EQUIVALENT LEVEL OF SAFETY DURING ANDREW L. CHROSTOWSKI’S 

PROPOSED OPERATIONS. THE ADMINISTRATOR HAS HELD THAT 

PRIOR DOCUMENTED FLIGHT EXPERIENCE THAT WAS OBTAINED IN 
29

COMPLIANCE WITH APPLICABLE REGULATIONS WOULD ENSURE SAFE 

OPERATIONS, STATING AS FOLLOWS:

IN EXEMPTION NO 11-62, THE FAA REQUIRED THAT PRIOR TO 

CONDUCTING OPERATIONS FOR THE PURPOSE OF MOTION PICTURE 

FILMING (OR SIMILAR OPERATIONS), THE PIC MUST HAVE 

ACCUMULATED AND LOGGED, IN A MANNER CONSISTENT WITH 14 

C.F.R. 61.51(B), 25 HOURS OF TOTAL TIME AS A UAS ROTORCRAFT PILOT 

INCLUDING AT LEAST 10 HOURS LOGGED AS A UAS PILOT WITH A 

MULTI-ROTOR UAS. PRIOR TO OPERATIONS UNDER EXEMPTION NO. 

11062, THE PIC MUST ALSO HAVE ACCUMULATED AND LOGGED A 

MINIMUM OF 5 HOURS AS A UAS PILOT OPERATING THE SAME MAKE 

AND MODEL OF UAS TO BE USED FOR OPERATIONS UNDER THE 

EXEMPTION. FOR CLARIFICATION, THE FAA CONSIDERS THESE 

MINIMUM HOUR REQUIREMENTS TO BE INCLUSIVE RATHER THAN 

ADDITIVE; I.E. 5 HOURS MAKE AND MODEL TIME MAY BE INCLUDED IN 

THE 10 HOURS OF MULTI-ROTOR TIME AND THE 10 HOURS MAY BE 

INCLUDED IN THE TOTAL 25 HOURS OF UAD ROTORCRAFT TIME. IN 

ADDITION TO THE HOUR REQUIREMENTS, THE PIC MUST ACCOMPLISH 

3 TAKEOFFS AND LANDINGS IN THE PRECEDING 90 DAYS (FOR 

CURRENCY PURPOSES). THE FAA FINDS THAT AT A MINIMUM, THE 

FLIGHT HOUR REQUIREMENTS IN EXEMPTION NO 11062 ARE 

APPROPRIATE TO PRACTICE AND BUILD PROFICIENCY IN THE SKILLS 

NECESSARY TO SAFELY CONDUCT THE PETITIONER’S PROPOSED 

OPERATIONS. THE FAA ALSO FINDS THAT PRIOR DOCUMENTED 

FLIGHT EXPERIENCE THAT WAS OBTAINED IN COMPLIANCE WITH 

APPLICABLE REGULATIONS WOULD SATISFY THIS REQUIREMENT. 

TRAINING, PROFICIENCY, AND EXPERIENCE-BUILDING FLIGHTS CAN 

ALSO BE CONDUCTED UNDER THE GRANT OF EXEMPTION TO 

ACCOMPLISH THE REQUIRED FLIGHT TIME. DURING TRAINING, 

PROFICIENCY, AND EXPERIENCE-BUILDING FLIGHTS THE PIC IS 

REQUIRED TO OPERATE THE UA WITH APPROPRIATE DISTANCES IN 

ACCORDANCE WITH 14 C.F.R. 91.119. EXEMPTION NO 11138 AT PAGE 15.

ACCORDINGLY, ANDREW L. CHROSTOWSKI WILL ENSURE SAFE 

OPERATIONS BY NOT ALLOWING ANY PIC TO OPERATE THE DJI 

INSPIRE 1 UAS UNLESS THAT PIC HAS DEMONSTRATED. BY MEETING 

MINIMUM FLIGHT-HOUR AND CURRENCY REQUIREMENTS, THAT THE 

PIC IS ABLE TO SAFELY OPERATE THE DJI INSPIRE 1 UAS IN A MANNER 

CONSISTENT WITH THE EXEMPTION, INCLUDING EVASIVE AND 
30

EMERGENCY MANEUVERS AND MAINTAINING APPROPRIATE 

DISTANCES FROM PEOPLE, VESSELS, VEHICLES, AND STRUCTURES.

CONCLUSION

ANDREW L. CHROSTOWSKI SEEKS AN EXEMPTION PURSUANT TO 

14 C.F.R. 11.61 AND SECTION 333 OF THE FAA MODERNIZATION AND 

REFORM ACT OF 2012 (FMRA), WHICH WILL PERMIT SAFE OPERATION 

OF THE DJI INSPIRE 1 UAS COMMERCIALLY, WITHOUT AN 

AIRWORTHINESS CERTIFICATE, FOR THE LIMITED PURPOSE OF 

CONDUCTING AERIAL VIDEO AND PHOTOGRAPHY OVER CERTAIN 

AREAS OF THE UNITED STATES. 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 ANDREW L. CHROSTOWSKI TO SAFELY, EFFICIENTLY, AND 

ECONOMICALLY OPERATE THE DJI INSPIRE 1 UAS COMMERCIALLY 

WITHIN THE NAS. THEREFORE, IN ACCORDANCE WITH THE FEDERAL 

AVIATION REGULATIONS AND THE FAA MODERNIZATION AND 

REFORM ACT OF 2012, SECTION 333, ANDREW L. CHROSTOWSKI 

RESPECTFULLY REQUESTS THAT THE ADMINISTRATOR GRANT THIS 

PETITION FOR AN EXEMPTION FROM THE REQUIREMENTS OF 14 C.F.R. 

SECTIONS 61.113 (A) AND (B), 91.7 (A), 91.121, 91.151 (B), 91.405 (A), 91.407 

(A)(1), 91.409(A)(1) & (A)(2), AND 91.417(A) & (B), AND PERMIT ELITE A/V 

SOLUTIONS TO OPERATE THE DJI INSPIRE 1 UAS COMMERCIALLY FOR 

THE PURPOSE OF CONDUCTING AERIAL VIDEO AND PHOTOGRAPHY 

OVER CERTAIN AREAS OF THE UNITED STATES

DATED: 12/21/2015

SUBMITTED BY

ANDREW L. CHROSTOWSKI
31

 

 APPENDIX - A

DJI INSPIRE 1 TECHNICAL SPECIFICATIONS

ANDREW L. CHROSTOWSKI ONLY UTILIZES SAFE AND RELIABLE UAS’S. 

DJI IS AN INDUSTRY LEADER IN SMALL UAS PRODUCTION. DJI UAS’S ARE 

LOADED WITH GROUND BREAKING SOFTWARE ENABLING THE USER TO SET 

PARAMETERS WHICH WILL NOT ALLOW FLIGHT INTO CONTROLLED 

AIRSPACE. PARAMETERS CAN ALSO BE SET TO LIMIT FLIGHT TO NO HIGHER 

THAN A PREDETERMINED AND SET ALTITUDE AS WELL AS LIMIT FLIGHT TO 

A PREDETERMINED AND SET DISTANCE. IN ADDITION, DJI SOFTWARE 

PROVIDES REAL-TIME ALTITUDE AND LOCATION INFORMATION TO THE PIC 

VIA THE LINKED MONITOR (SMART PHONE/TABLET DEVICES).

1.1 DJI INSPIRE 1

1.2 1.1.1 AIRCRAFT

1.1.1.1 SUPPORTED BATTERY - DJI 4500MAH LIPO BATTERY

1.1.1.2 WEIGHT (BATTERY & PROPELLERS INCLUDED) - 6.5LBS

103.529OZ (83,205G)

1.1.1.3 HOVER ACCURACY (READY TO FLY) - VERTICAL: 0.5M;

HORIZONTAL: 2.5M

1.1.1.5 MAX TILT ANGLE - 35 DEGREES

1.1.1.6 MAX ASCENT SPEED - 5 M/S

1.1.1.7 MAX DECENT SPEED - 4 M/S

1.1.1.8 MAX FLIGHT SPEED - 22 M/S (ATTI MODE, NO WIND, NOT

RECOMMENDED)

1.1.2 GIMBAL

1.1.2.1 WORKING CURRENT - STATIC: 750MA; DYNAMIC: 900MA

1.1.2.2 CONTROL ACCURACY - +/-.03 DEGREES

1.1.2.3 CONTROLLABLE RANGE - PITCH: -90 DEGREES TO 30

DEGREES PAN: +/- 320 DEGREES
32

1.1.2.4 MAXIMUM ANGULAR SPEED - PITCH: 120 DEGREES/S 

PAN: 180 DEGREES/S

1.1.3 CAMERA

1.1.3.1 OPERATING TEMPERATURE RANGE - 0 TO 40 DEGREES C

1.1.3.2 SENSOR SIZE - 1 / 2.3”

1.1.3.3 EFFECTIVE PIXELS - 12.4M

1.1.3.4 RESOLUTION - 4000X3000

4.1.3.5 HD VIDEO RECORDING - UHD (4K): 4096X2160P24/25,

3840X2160P24/25/30

FHD: 1920X1080P24/25/30/48/50/60

HD: 1280X720P24/25/30/48/50/60

4.1.3.6 RECORDING FIELD OF VIEW - 94 DEGREES

APPENDIX - B

DJI INSPIRE 1 USER MANUAL

HTTP://WWW.DJI.COM/PRODUCT/INSPIRE-1/INFO#DOWNLOADS
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