1 IN THE MATTER OF THE PETITION FOR EXEMPTION OF: ABOVE ALL VIDEO LLC FOR AN 

EXEMPTION SEEKING RELIEF FROM THE REQUIRMENTS OF TITLE 14 OF THE CODE OF 

FEDERAL REGULATIONS SECTIONS 61.113 (a) and (b); 91.7 (a); 91.119 (c); 91.121; 91.151 (a); 

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

Submitted on 4/25/2015 By, Nicholas Macray Fuller Above All Video LLC (252) 622.1783 

SUMMARY ABOVE ALL VIDEO LLC, seeks exemptions from Title 14, Code of Federal Regulations §§ 

61.113 (a) and (b), 91.7 (a), 91.119, 91.121, 91.151 (a), 91.405 (a), 91.407 (a)(1), 91.409 (a)(1) and (2), 

91.417 (a) and (b) to operate a DJI INSPIRE 1 UAS. This exemption will allow ABOVE ALL VIDEO

LLC to operate an Unmanned Aerial Vehicle commercially for the purpose of conducting aerial 

videography and photography in the real estate and construction markets of North Carolina. These images 

and videos will provide community awareness and geospatial understanding. 

INTRODUCTION TO PETITIONER ABOVE ALL VIDEO LLC, is a real estate videography and 

photography company specializing in producing high quality results for clients who want digital displays of 

MLS listings. ABOVE ALL VIDEO LLC seeks relief to use an Inspire 1 quad-copter to commercially 

capture video of listings while working on private property. ABOVE ALL VIDEO LLC will utilize a 

Visual Observer (V.O.) while maintaining Visual Line of Sight (V.L.O.S.) between the quad-copter and a 

UAV operator. 

The UAV INSPIRE 1 The DJI Inspire 1 is a quad-rotor Unmanned Aircraft System (UAS) weighing less 

than 2935 grams. The Inspire 1 UAS that ABOVE ALL VIDEO LLC will be responsible for also utilizes a 

mobile ground station. The UAS features a safety Return to Home function that in the event of a signal 

loss, the 4 UAS will return to a preset position and land. The Return to Home feature can also be triggered 

manually. INSPIRE 1 uses a 2.4GHz RC system. To avoid communication interference, ABOVE ALL 

VIDEO LLC will not use other 2.4GHz devices (including 2.4G Wi-Fi or 2.4G wireless video transmission 

module). The Inspire 1 can fly at approximately 22 m/s. Above All Video LLC has no need to operate at a 

speed greater than 15 m/s. The Inspire 1 is powered by a single Lipo battery. This battery gives the Inspire 

1 an approximate 18 minutes worth of flight time with its attached payload of a X3 camera and the 

associated gimbal that connects the camera to the quad-copter. 

BASIS FOR PETITION ABOVE ALL VIDEO LLC pursuant to the provisions of the Federal Aviation 

Regulations (14 C.F.R. § 11.61) and the FAA Modernization and Reform Act of 2012, Section 333, Special 

Rules for Certain Unmanned Aircraft Systems, hereby petitions the Administrator to operate the DJI 

INSPIRE 1 UAS within the National Airspace System, and for an exemption from the requirements of 14 

C.F.R. §§ 61.113 (a) and (b), 91.7 (a), 91.119, 91.121, 91.151 (a), 91.405 (a), 91.407 (a)(1), 91.409 (a)(1) 

and (2), 91.417 (a) and (b). A. Name and Address of The Petitioner ABOVE ALL VIDEO LLC 219B West 

Atlantic Blvd. Atlantic Beach, North Carolina, 28512. info@aboveallvideonc.com 

ABOVE ALL VIDEO LLC Requests Relief from the Following Sections of 14 C.F.R. 1. Sections 61.113, 

entitled Private pilot privileges and limitations: Pilot in Command, Subsections (a) and (b) prescribed the 

following, in part: (a) No person who holds a private pilot certificate may act as a pilot in command (PIC) 

of an aircraft that is carrying passengers or property 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 incidental to that 

business or employment and (2)The aircraft does not carry passengers or property for compensation or hire. 

2. Section 91.7, entitled Civil airworthiness, subsection (a), states the following: (a) No person may operate 

a civil aircraft unless it is in an airworthy condition. 3. Section 91.119, entitled Minimum Safe Altitudes: 

General Except when necessary for takeoff or landing, no person may operate an aircraft below the 

following altitudes: (a) Anywhere, An altitude allowing, if a power unit fails, an emergency landing 

without undue hazard to persons or property on the surface. (b)Over congested areas. An altitude of 1000 

feet above the highest obstacle within a horizontal radius of 2000 feet of the aircraft. (c) Over other than 

congested areas. An altitude of 500 feet above the surface, except over open water or sparsely populated 

areas. In those cases, the aircraft may not be operated closer than 500 feet to any person, vessel, vehicle or 
structure. (d)Helicopters, powered parachutes, and weight-shift-control aircraft. If the operation is 

conducted without hazard to persons or property on the surface— 6 (1)A helicopter may be operated a t 

less than the minimums prescribed in paragraph (b) or (c) of this section, provided each person operating 

the helicopter complies with any routes or altitudes specifically prescribed for helicopters by the FAA; and 

(2)A powered parachute or weight-Shift-Control aircraft may be operated at less than the minimums 

prescribed in paragraph © of this section. 4. Section 91.121, entitled Altimeter Settings, subsection (a), 

states the following, in relevant part: (a) Each person operating an aircraft shall maintain the cruising 

altitude of flight level of that aircraft, as the case may be, by reference to an altimeter that is set, when 

operating— (1)Below 18,000 feet MSL, to— (i) The current reported altimeter setting of a station along the 

route and within 100 nautical miles of the aircraft; (ii) If there is not station within the area prescribed in 

paragraph (a)(1)(i) of this section, the current reported altimeter setting of an appropriate available station; 

or (iii) In the case of an aircraft not equipped with a radio, the elevation of the departure airport or an 

appropriate altimeter setting available before departure; 5. 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 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. 6. Section 91.405, entitled Maintenance required, subsection (a) stated 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 required inspection, except as provided in 7 paragraph (c) of this section, have 

discrepancies repaired as prescribed in part 43 of this chapter. 7. Section 91.407(a)(1), entitled Operation 

after maintenance, preventive maintenance, rebuilding, or alteration, subsections (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 a person 

authorized under §43.7 of this chapter. 8. 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. 9. 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— 8 (i) A description (or 

reference to data acceptable to the Administrator) or the work performed; and (ii) The date of completion of 

the work performed; and (iii) The signature, and certificate number of the 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 net 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. a. The Owner 

or operator shall retain the following records for the periods prescribed: (1)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 the work is performed. (2)The records specified in paragraph (a)(2) of this sections shall be 

retained and transferred with the aircraft at the time the aircraft is sold. (3)A list of defects furnished to a 

registered owner or operator under § 43.11 of this chapter shall be retained until the defects are repaired 

and the aircraft is approved for return to service.

The Extent Of Relief That ABOVE ALL VIDEO LLC Seeks 1. Extent of Relief that ABOVE ALL VIDEO

LLC Seeks Regarding Section 61.113 (a) and (b) Private Pilot Privileges and Limitations Relief from 

Section 61.113 (a) and (b) is requested to allow a Pilot in Command not holding a current Private Pilots 
Certificate to operate the ABOVE ALL VIDEO Inspire 1. The flight would be complimented by a Visual 

Observer who, along with the pilot, will maintain Visual Line of Sight with the Inspire 1 at all times. All 

operations conducted will be incidental to Above All Video LLC’s business. The Inspire 1 is not able to 

carry passengers. 2. Extent of Relief that ABOVE ALL VIDEO seeks in Regards to Section 91.7(a) Civil 

Aircraft Airworthiness Relief from Section 91.7(a) is requested to allow ABOVE ALL VIDEO to 

determine airworthiness of the Inspire 1. As part of this determination the following will be adhered to: a. 

Prior to the Inspire 1’s flight the PIC will inspect the UA to ensure it is in a condition that will be 

conducive for a safe flight. The ground control station will be included in the above inspection. b. ABOVE 

ALL VIDEO will follow the DJI Inspire 1’s aircraft/component, maintenance, overhaul, replacement, 

inspection and life limit requirements. c. ABOVE ALL VIDEO will comply with all DJI manufacturer 

Safety Bulletins. 3. Extent of Relief that ABOVE ALL VIDEO seeks in Regards to Section 91.119 

Minimum Safe Altitudes General 10 Relief from 91.119 is requested to allow ABOVE ALL VIDEO to 

operate the Inspire 1 at altitudes not to exceed 400’ AGL over private property at a distance at or greater 

than 5NM from the nearest airport as depicted on current Aeronautical Charts. ABOVE ALL VIDEO also 

wishes to be granted exemption to operate at an altitude not greater than 50’ AGL (below tree level) 

between 1NM and 5NM from the nearest airport as depicted on current Aeronautical Charts. ABOVE ALL 

VIDEO will adhere to the following in order to maintain an acceptable level of safety associated with 

operations over private property: (a) ABOVE ALL VIDEO will display signs in the immediate vicinity of 

operations stating: “Aerial Photography In Progress. Use Caution.” (b)ABOVE ALL VIDEO will not allow 

the Inspire 1 to operate at a speed greater than 22 m/s. (c) ABOVE ALL VIDEO will require the UAS 

operator (PIC) to be fully trained on the Inspire 1 by adhering to the recommendations contained within the 

Inspire 1’s operating manual. (d)ABOVE ALL VIDEO’s UAS operator (PIC) will have accumulated and 

logged, in a manner consistent with 14 CFR 61.51(b), a minimum of 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. In addition the 

operator will have logged a minimum of 5 hours as a UAS pilot operating the make and model UAS that 

ABOVE ALL VIDEO operates. (e) ABOVE ALL VIDEO’S UAS operator (PIC) will be familiar with and 

able to manually institute the Inspire 1’s Return to Home (RTH) feature. This feature aborts a flight 

operation and automatically returns the UAS to a predetermined GPS safe point. (f) ABOVE ALL 

VIDEO’s UAS operator (PIC) will not operate over private property without first finding a suitable 

alternate landing spot on the property. (g)ABOVE ALL VIDEO’s UAS operator (PIC) will abort the flight 

in the event of unpredicted obstacles or emergencies in accordance with the operating documents. 11 

(h)ABOVE ALL VIDEO will utilize a two man flight team consisting of the Pilot in Command (PIC) and a 

Visual Observer (VO). This team will maintain visual line of sight with the Inspire 1 at all times and 

remain within hearing of one another. (i) ABOVE ALL VIDEO will not permit flight around vessels, 

vehicles and structures without permission from the owner. 4. Extent of Relief that ABOVE ALL VIDEO

Seeks in Regards to Section 91.121 Altimeter Settings Relief from 91.121 is requested because the Inspire 

1 utilizes electronic GPS with a barometric sensor. In order to maintain an equal level of safety that 91.121 

requires, the PIC of the ABOVE ALL VIDEO UAS will abort the flight in the events that the UA loses 

communications with the GPS signal. 5. Extent of Relief that ABOVE ALL VIDEO Seeks in Regards to 

Section 91.151(b) Fuel Requirements for Flight in VFR Conditions Relief from 91.151(b) is requested to 

the extent that allows ABOVE ALL VIDEO to operate the Inspire 1 up to a point (considering wind and 

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

landing point and land the UA with 30% battery power remaining. 6. Extent of Relief that ABOVE ALL 

VIDEO Seeks in Regards to Sections 91.405(a), 91.407(a)(1), 91.409(a)(1), and (a)(2), 91.417(a) and (b) 

These are all associated a with Airworthiness certificate Relief from 91.405(a), 91.407(a)(1), and (a)(2), 

And 91.417(a) and (b) is requested to the extent that allows ABOVE ALL VIDEO to operate the Inspire 1

Quad-Copter as necessary. These sections are all related to airworthiness certificates of aircraft. There is 

not currently an airworthiness certificate for small UAS’s. ABOVE ALL VIDEO would comply in full to 

any conditions and limitations that the Administrator would place in order to receive an approved Grant of 

Exemption.