22 December 2014

U.S. Department of Transportation 

Docket Management System 

1200 New Jersey Ave., SE 

Washington, DC 20590

Re: Exemption Request Under Section 333 of the FAA Reform Act and Part 11 of the Federal Aviation 

Regulations

Dear Sir or Madam:

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

C.F.R. Part 11, Celestial Imaging LLC, seeks an exemption from Federal Aviation Regulations (“FARs”) 

detailed below for the DJI Inspire 1, a quadcopter manufactured by DJI-Innovations.

The requested exemption would support an application for a commercial Certificate of Authorization to 

use the system to support aerial photography and videography. The DJI Inspire 1 system consists of a 

lightweight (6.5 lb) battery operated aircraft, a tablet-based ground control station and/or RC Controller, 

and associated communications equipment. The aircraft carries an onboard geo-referenced gimbaled

camera that allows it to obtain photography and videography. The ability to gather high resolution photo 

and video has been requested by the tourism departments of several states. 

The ability to obtain imagery that would otherwise be impossible to obtain (the UAV has the ability to 

follow scenic river courses through areas with dense tree canopies) or very difficult or costly allows them 

more freedom to promote the natural wonders of their states. This will increase tourism revenue and aid 

the state and local economies on a more environmentally friendly, more economic, and a safer basis. In 

these wildlife environments, the less noise pollution that you can produce, the better it is for the habit of 

the native species found there.

The aircraft will be operated in the field with both a Pilot in Command (PIC) and a ground-based Visual 

Observer (VO) in accordance with FAA Policy N 8900.227 Section 14 "Operational Requirements for 

UAS" with the following additional restrictions: 

- All operations will occur in Class G airspace at no more than 400' AGL 

- Operations will only be conducted with permission from the appropriate land owner

- All required permits will be obtained from state and local government prior to operation 

- The aircraft will not be operated over populated areas as defined on FAA sectional maps

- The aircraft will not be operated at air shows or over an open-air assembly of people 

- The aircraft will not be operated over heavily trafficked roads 

- The aircraft will not be operated within 5 NM of a public airport or heliport 

- Operations will be limited to day, visual meteorological conditions 

- Aircraft will remain within Visual Line of Sight at no greater than 1/4 NM of the PIC at all time 

- While the aircraft is airborne, the VO will be positioned within voice distance to the PIC 

- PIC will file a NOTAM providing radial/DME, radius, and a date/time group for each operation a 

minimum of 72 hours before any planned flight activity
The PIC and VO will meet the requirements outlined in FAA Policy N 8900.227 Section 16 Personnel 

Qualifications. Additionally, the PIC and VO will perform maintenance on the system and will complete 

a course of maintenance instruction as part of their initial training. Due to the simplicity of the system, we 

do not anticipate the need for a supplemental pilot.

We submit that the combination of the aircraft's light weight, the autopilot’s demonstrated flight 

performance, fully qualified flight crew and strict operation under the guidelines established in 8900.227, 

the FAA can have confidence that the operation will have an equivalent or greater level of safety of 

manned aircraft performing the same mission.

The name and contact information of the applicant are: 

Celestial Imaging LLC 

Attn: Matt Balderree 

Ph: 208-599-4324

Email: Celestialphotographics@gmail.com 

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

- 14 CFR Part 21 

- 14 CFR 91.203 

- 14 CFR 45.23, 45.29 

- 14 CFR 91.9 

- 14 CFR 61.113, 61.133 

- 14 CFR 91.109, 91.119 

- 14 CFR 91.121, 91.151 

- 14 CFR Subpart E (91.401 - 91.417) 

- FAA Policy 8900.227 Paragraph 16(c)(4) and Paragraph 16(e)(1) 

We are prepared to modify or amend any part of this request to satisfy the need for an equivalent level of 

safety. We look forward to working with your office. Please contact us at any time if you require 

additional information or clarification. 

Sincerely,

Matthew L. Balderree

President Celestial Imaging

Appendices:

A. Exemption Request and Equivalent Level of Safety

B. Privacy Issues

C. Safety Case

D. Maintenance Procedures/POH

E. Aviation Experience