MEDIA / / STRATEGY / / CREATIVE / / INTEGRATION

970.456.0011 / / ALIGNMULTIMEDIA.COM / / INFO@ALIGNMULTIMEDIA.COM / /

110 EAST THIRD STREET, SUITE 103 // RIFLE, CO 81650

OPERATOR’S NAME AND ADDRESS

Ryan Mackley

Align Multimedia, LLC

110 E 3rd Street, Suite 103

Rife, CO 81650

(970) 456-0011 (Offce)

(970) 319-2073 (Cell)

ryan@alignmultimedia.com

U.S. DEPARTMENT OF TRANSPORTATION 

Docket Management System

1200 New Jersey Ave., SE 

Washington, DC 20590

RE: Exemption Request Section 333 of the FAA Reform Act of 2012

Dear Administrator,

In accordance with the FAA’s Guidelines for Submitting a Petition for Exemption under section 

333 of the FAA Modernization and Reform Act of 2012, Align Multimedia, LLC, referred to 

hereafter as the petitioner, requests exemption from the following sections of Title 14, Code of 

Federal Regulations§§: 14 C.F.R. §§ Part 21, 61.113(a) & (b), 91.119(c), 91.121, 91.151(a) 

& (b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) in order to operate 

small unmanned aircraft systems (UAS) commercially in the National Airspace System (NAS) 

regulated by the Federal Aviation Administration (FAA) for the purposes of aerial photography, 

cinematography, videography.

Operations will be conducted within and under the conditions outlined herein or as may be 

established by the FAA as required by Section 333.

SUMMARY

The proposed exemptions, if granted, would allow Align Multimedia, LLC to operate an 

Unmanned Aircraft System (UAS) within the National Airspace System (NAS) pursuant to 

Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA). This exemption will 

permit the petitioner to operate an UAS for the commercial purpose of producing aerial video 

cinematography and photography of residential and commercial real estate, oil and gas industry 

sites, landscapes and events.
MEDIA / / STRATEGY / / CREATIVE / / INTEGRATION

970.456.0011 / / ALIGNMULTIMEDIA.COM / / INFO@ALIGNMULTIMEDIA.COM / /

110 EAST THIRD STREET, SUITE 103 // RIFLE, CO 81650

INTRODUCTION

Align Multimedia, LLC is a digital marketing and advertising company located in western 

Colorado. Our ownership and staff have more than 25 years’ experience creating video and 

photo assets for our clients without any safety issues on any of our projects. In the past, 

we have rented commercial aircraft in order to provide our clients with aerial video and 

photography. With the advent of small UAS technology, we can now make this product more 

cost-effective for our clientele. Our aim is to use our UAS system to provide high quality aerial 

images to a wide variety of governmental, commercial, and private clients, specifcally targeting:

• Oil and Gas Industry Production Facilities

• Commercial Real Estate

• Scenery and Outdoor Sports

• Economic Development Projects

• Special Events

• Government Agency Training

Our Pilot in Command (PIC), Ryan Mackley, has been fying small UAS vehicles as a hobbyist 

(not for compensation) for more than fve years without incident. In particular, he has fown the 

DJI Inspire 1 for the last 6 months, is very knowledgable about its safe operation, and has not 

had a safety incident with the aircraft. 

AIRCRAFT INFORMATION

The unmanned aircraft (UA) to be used by Align Multimedia in the proposed operations is a DJI 

Inspire 1. This unmanned, radio-controlled UA weighs less than 6.5 pounds with dimensions 

of 17.24 x 17.76 x 11.85 inches. This is a four rotor UAS powered by an on-board battery. 

The operating area of this aircraft is limited by both the radio control signal and the battery life. 

The manufacturer rates the maximum fight distance from the PIC as 1.2 miles. The maximum 

range of the radio controller is 3.1 miles from the PIC but we envision the maximum fight 

distance in our proposed operations to be closer to a 1 mile maximum distance from the PIC 

under visual line of sight at all times.

The aircraft will automatically return to the point of take-off in the instance of a loss of signal 

from the control device.

The UA has a built-in gimbaled camera system that records still photos as well as highdefnition video.
MEDIA / / STRATEGY / / CREATIVE / / INTEGRATION

970.456.0011 / / ALIGNMULTIMEDIA.COM / / INFO@ALIGNMULTIMEDIA.COM / /

110 EAST THIRD STREET, SUITE 103 // RIFLE, CO 81650

DJI Inspire 1 Full Specifcations List: http://www.dji.com/product/inspire-1/info#specs

DJI Inspire 1 Manual: https://dl.djicdn.com/downloads/inspire_1/en/Inspire_1_User_Manual_

en_v2.0_1218.pdf

RELIEF SOUGHT

Generally, Align Multimedia, LLC seeks exemption from the above referenced requirements in 

order to operate the DJI Inspire 1 UAS in the National Airspace System (NAS) for commercial 

video and still image gathering purposes.

SPECIFICALLY, WE SEEK RELIEF AS FOLLOWS:

14 C.F.R. Part 21

The petitioner seeks relief because the UAS to be used (DJI Inspire 1) is small, unmanned, and 

does not carry fuel. Therefore, most of spirit of Part 21 does not apply. As such, the petitioner 

asks for either an exemption from the requirement of an airworthiness certifcate altogether or 

for the designation of an experimental certifcate under 21.191 (a) and/or (b). 

61.113(a) & (b)

The petitioner seeks relief in order to allow an experienced UAS pilot (PIC) and a visual observer 

to operate the UAS in the NAS for commercial purposes. All pre-fight inspection, maintenance 

and fight logs will be made available to interested authorities for review upon request. All 

safety measures listed in the “Safety” section below will be followed.

91.119(c)

As discussed in Exemption 11138 (DOUGLAS TRUDEAU), operations conducted at altitudes 

less than 500 feet may necessitate that the UAS be operated closer than 500 feet to people, 

or objects. These operations would not be possible without additional relief. The petitioner 

requests waiver for this condition to allow reasonable and responsible operations in housing 

subdivisions and neighborhoods for multiple purposes, the most common of which will be the 

production of real estate video.

In areas where there are houses, streets and people in the open, the petitioner will primarily 

operate the UAS between ground level and 200 feet. The petitioner will not operate the UAS 

over the head of any person without their knowledge and express consent. The UAS will be 

operated over private property only with the owner’s consent. The petitioner will compile fight 

data from the logs generated by the fight software which will be available for review.
MEDIA / / STRATEGY / / CREATIVE / / INTEGRATION

970.456.0011 / / ALIGNMULTIMEDIA.COM / / INFO@ALIGNMULTIMEDIA.COM / /

110 EAST THIRD STREET, SUITE 103 // RIFLE, CO 81650

91.121

As discussed in Exemption 11138 (DOUGLAS TRUDEAU) this rule is inapplicable since the UAS 

does not have an altimeter. The DJI Inspire 1 instead utilizes electronic GPS with a barometric 

sensor for altitude information.

91.151(a) & (b)

As discussed in Exemption 11136 (ADVANCED AVIATION SOLUTIONS LLC) prior relief has 

been granted for manned aircraft to operate at less than the prescribed minimum altitudes. 

Additionally, UAS relief has been granted in Exemption Nos. 8811, 10808, and 10673 for 

daytime, VFR conditions. The petitioner’s proposed UAS provides battery power remaining in 

percent to the PIC. The UAS batteries provide18-25 minutes of powered fight and, as a matter 

of procedure, the UAS will be safely landed when battery capacity reaches 20% or less.

91.405(a); 91.407(a)(1); 91.409 (a)(1) & (a)(2); 91.417(a) & (b)

As discussed in Exemption 11138 (DOUGLAS TRUDEAU), Align Multimedia, LLC proposes that 

the petitioner’s PIC and visual observer will inspect and ensure that the UAS is in a condition 

for safe fight in accordance with the operating manual supplied by the manufacturer and the 

petitioner’s own procedural documentation. This inspection will be done prefight. There will 

also be a monthly maintenance inspection of the UAS. Following these processes will ensure 

safe operation of the UAS.

SAFETY

Align Multimedia believes that proper use of the DJI Inspire 1 UAS will increase safety as 

compared to our prior use of manned aircraft to capture aerial photo and video. The UAS is 

smaller, slower, quieter and does not contain potentially fammable aviation fuel.

To further promote safety, Align will follow the following procedures:

Requirements of Pilots in Command

No person will be granted Pilot in Command status unless they have met the following 

requirements:

1. Thorough knowledge of the DJI Inspire Aircraft System and Software

2. At least 50 hours fight experience with the DJI Inspire 1 or similar UAS.

3. Familiarity with all Align Multimedia prefight procedures.

4. Thorough knowledge of all conditions and limitations cited by the FAA in the herein 

requested grant of exemption.
MEDIA / / STRATEGY / / CREATIVE / / INTEGRATION

970.456.0011 / / ALIGNMULTIMEDIA.COM / / INFO@ALIGNMULTIMEDIA.COM / /

110 EAST THIRD STREET, SUITE 103 // RIFLE, CO 81650

5. Will have knowledge of the location of all commercial and private airports within a 50 mile 

radius of the fight area.

6. Will pre-inspect the intended fight path for potential obstacles, including but not limited to, 

buildings, power lines, trees and transmission towers.

7. Will not surrender operational control of the UAS to anyone not meeting the PIC 

requirements set forth above.

8. Will log fight details including hours and maintenance conducted.

9. Will read and know the UAS manufacturer’s safety guidelines. (http://dl.djicdn.com/

downloads/inspire_1/en/Inspire_1_Safety_Guidelines_and_Disclaimer_v1.2_en.pdf)

PREFLIGHT PROCEDURES

The PIC will always make a series of pre-fight checks and processes which include (but will not 

be limited to) the following:

1. Conduct a thorough physical inspection of the aircraft to make sure that the aircraft is in 

proper condition for safe fight. Check rotors to ensure that they are properly attached. If a 

problem is detected, the aircraft will not be fown until the problem is fxed.

2. Perform magnetic calibration according to the aircraft manufacturer’s instructions to ensure 

proper confguration.

3. Ensure that fight conditions are conducive to safe fight. Manufacturer limits on maximum 

launch altitude, air temperature and wind speed will be checked and observed.

4. The intended fight path will be visually inspected for potential obstacles.

5. Ensure that GPS connections are numerous enough for aircraft to accurately mark its takeoff point to store it in memory. The Inspire 1 is capable of returning back to the take-off 

point if connection signal to the controller is lost by the aircraft.

6. Ensure that the visual observer (VO) is aware of all procedures and has double-checked 

PIC’s completion of them prior to fight.

FLIGHT PROCEDURES

1. Flight altitude will not exceed 400 feet from ground level.

2. The aircraft will remain within Visual Line of Sight of the PIC and/or the visual observer for 

the entire fight. Operating the UAS inside of cloud cover will not be permitted.

3. A visual observer (VO) will accompany the PIC for all fights.

4. Battery life will be closely observed and fights will return to the PIC and the landing zone 

when battery reserves diminish to 20% of capacity.
MEDIA / / STRATEGY / / CREATIVE / / INTEGRATION

970.456.0011 / / ALIGNMULTIMEDIA.COM / / INFO@ALIGNMULTIMEDIA.COM / /

110 EAST THIRD STREET, SUITE 103 // RIFLE, CO 81650

AIRCRAFT MAINTENANCE

1. In addition to the Pre-Flight check, the aircraft will undergo a monthly maintenance check 

according to the manufacturer’s suggested maintenance checklist.

PUBLIC INTEREST

Align Multimedia commonly works with local governmental agencies to provide video and photo 

content that assists these organizations with tourism marketing and economic development. 

There is a strong demand amongst these groups to acquire more assets to further build the 

tourism economy in the region. Aerial imagery also helps to market property for development, 

thereby boosting the regional economy.

There is also a strong demand in the energy industry in the region to obtain aerial imagery to 

assist with reclamation efforts. Minimizing the environmental impacts of the industry is very 

much in the public interest.

There is a need in our region for an alternative to the high expense of renting commercial 

aircraft in order to obtain high quality video and photo images. By allowing for this exemption, 

the FAA will be opening up a new product offering to a wide range of private and public 

organizations.

CONCLUSION

The petitioner respectfully requests exemption under Section 333 to enable Align Multimedia, 

LLC to fulfll its intention to safely conduct UAS operations in the NAS for all of the activities 

stated. Thank you for your time and consideration.

Sincerely

Ryan Mackley

Owner - Align Multimedia, LLC