November 25, 2015

U.S. Department of Transportation

Docket Management System

1200 New Jersey Ave. SE

Washington, DC 20590

Exemption Request Section 333 of the FAA Reform Act

To Whom It May Concern,

In accordance with Section 333 of the FAA Modernization and Reform Act of 2012 and 14

C.F.R. Part 11, Bilal E Mustafa​, hereby applies for exemptions from the following Federal

Aviation Regulations (FARs) in order to operate a Small Unmanned Aircraft System (sUAS) for

commercial applications in airspace that is governed by the Federal Aviation Administration

(FAA). All flight operations will be conducted under the conditions and boundaries outlined

herein or as established by the FAA in accordance with Section 333.

The exemptions, as requested by Bilal E Mustafa​, would permit the provision of commercial

services to customers that are in need of aerial data capture from a sUAS. Bilal E Mustafa

requests these exemptions in order to perform commercial flights in the following areas:

● Surveying

● Agriculture

● Aerial Inspection

● Real Estate Photography

● General Photography

● Special Events

All flights will be conducted over private or controlled access property with the consent and

knowledge of the property owner or controlling party. All flight operations will maintain a 500 foot

buffer from all nonparticipating persons, vessels, vehicles, and structures unless sufficient

barriers are in place to protect nonparticipating persons from undue harm. Flight operations will

also only be operated near vessels, vehicles, and structures where the property owner/controller

has granted permission and a safety assessment has been made.

Regulations from which an exemption is requested:

14 CFR 61.113(a)

14 CFR 91.7(a)

14 CFR 91.119(c)

14 CFR 91.121

14 CFR 91.151(a)

14 CFR Subpart E (91.401 – 91.417)
THE UNMANNED AIRCRAFT SYSTEM

Due to the low cost of operation, increased safety to surrounding persons and property, reduced

noise and environmental impact, and the versatility of the sUAS platform, we believe that a

sUAS can be a great solution to consumers who would, otherwise, have to hire a larger aircraft,

such as a helicopter, in order to capture the data that they need.

Bilal E Mustafa is seeking this exemption in order to operate a DJI Inspire 1 advanced

quadcopter equipped with a 3­axis gimbal and 4K camera. The DJI Inspire 1 has a maximum

gross weight of 6 pounds 7.5 ounces, a length of 17.3 inches, width of 17.7 inches, height of

11.8 inches, and a maximum speed of approximately 42 knots.DJI Inspire 1 UAs are equipped

with four main rotors; driven by Lithium Polymer battery powered electric motors. DJI safety

failsafe features equipped ensuring safe operations include:

● Geo­fence capability that will limit the height and horizontal distance that the Inspire 1

can fly from the operator.

● RTL mode­ In the case of low battery or lost communication between the Inspire

1 and the operator, the Inspire 1 will return to the point of takeoff and land itself.

● This mode can be manually turned on by the operator at any point in the flight.

● Land mode­ Loss of GPS signal will engage land mode. The Inspire 1 will land

automatically at its current position if in a flight mode that requires GPS signal.

● Telemetry radio communication provides real time feedback of flight data,

including current altitude, latitude, altitude change rate, and GPS coordinates.

Aforementioned safety features have undergone rigorous testing procedures by DJI as well as

by Bilal E Mustafa​.

FLIGHT OPERATIONS

The operator and PIC will guarantee that operations adhere to strict standards as set below:

The PIC must show that they are able to safely operate the UAS in a safe manner

before proceeding with operations.

● The UA will be operated at airspeeds below 29 knots.

● The UA will be operated below 400 feet above ground level (AGL) at all times.
● The UA will be operated within visual line of sight (VLOS) at all times.

● All operations will utilize a visual observer (VO). The UA will be operated within the

visual line of sight (VLOS) of the PIC and VO at all times.

● The VO will not perform any other duties beyond assisting the PIC with seeing and

avoiding traffic and other ground based obstacles.

● Proper preflight inspections will take place before each flight.

● The UA may not operate within 5 nautical miles of an airport reference point unless a

letter of agreement with that airport’s management is obtained.

● The UA 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.

● The PIC must maintain a battery reserve that allows the UA to return to point of landing

at normal cruise speed and land with 30% battery power.

● The UA must remain clear of and yield to all other air traffic.

● Flight operations will remain 500 feet from all nonparticipating persons, vehicles,

and structures unless:

a. Barriers or structures are present that sufficiently protect nonparticipating

persons from debris in the event of an accident.

b. All participating persons will be made aware of the dangers of flying a UA and

the safety precautions and features that are in place.

c. The aircraft is operated near vessel, vehicles, or structures where the property

owner/controller has granted permission and the PIC has made a safety

assessment in regard to the close operation to these objects.

d. Operations near the PIC or VO do not present an undue hazard to the PIC or

VO per 91.119(a).
● All operations will be conducted over private or controlled­access property with prior

permission from the property owner/controller or authorized representative.

By following the strict safety standards set by Bilal E Mustafa​, the FAA​, and the physical safety

properties of the sUAS, will allow for safe and efficient operations.

Bilal E Mustafa hereby requests exemption under Section 333 in order to pursue commercial

sUAV applications with the intent to provide customers with the safest, highest quality platform

available.

Sincerely,

BILAL E MUSTAFA

15888 SW 95TH AVE APT 221

MIAMI FLORIDA 33157

305­726­7278

EXEMPTION REQUESTS AND EQUIVALENT LEVEL OF SAFETY

Bilal E Mustafa requests an exemption from the following regulations as well as any additional

regulations found by the FAA to be necessary for safe and efficient UAS flight operations.

14 CFR 61.113(a), Private pilot privileges and limitations: Pilot in command

This regulation states that no person holding a private pilot certificate may act as pilot in

command of an aircraft that is carrying passengers or property for compensation or hire; nor

may that person, for compensation or hire, act as pilot in command of an aircraft.

We believe that a PIC with a private pilot license has sufficient skill and knowledge to complete

operations, especially after completing a sUAS knowledge and training course. We do not think

that a commercial pilot license will significantly improve a PIC’s performance while operating a

UAV.

Therefore, we ask for an exemption from 14 CFR 61.113(a) in order to operate commercially

with the minimum of a private pilot license.
14 CFR 91.7(a) Civil aircraft airworthiness

As a UAS will not require an airworthiness certificate, we believe that this regulation is not

applicable. Therefore, we request exemption from this regulation.

14 CFR 91.119(c) Minimum safe altitudes

This regulation states that no person may operate an aircraft below 500 feet above the surface

as well as within 500 feet of any person, vessel, vehicle, or structure.

We believe that, because of the nature of most UAS operations, an exemption is required in

order to allow operation closer than 500 feet to vessels, vehicles, or structures as long as

permission is granted from the owning/controlling parties and an assessment is made to assure

that people and property are safe from undue harm. We also request that operations be allowed

over congested areas as long as the operations stay within the following standards:

● Flight operations will remain 500 feet from all nonparticipating persons, vehicles, and

structures unless:

a. Barriers or structures are present that sufficiently protect nonparticipating persons

from debris in the event of an accident.

b. Participating persons are made aware of the dangers of the UAS operation

and the safety precautions that have been put into place.

c. The aircraft is operated near vessel, vehicles, or structures only where the property

owner/controller has granted permission and the PIC has made a safety assessment in

regard to the close operation to these objects.

d. Operations near the PIC or VO do not present an undue hazard to the PIC or VO per

91.119(a).

e. All operations will be conducted over private or controlled­access property with prior

permission from the property owner/controller or authorized representative.

14 CFR 91.121 Altimeter settings

As our UAS does not utilize a standard barometric altimeter, we request exemption from 91.121

to the extent necessary to comply with applicable conditions and limitations. The altimeter

reading for our UAS is calculated by GPS. The accurate and continuous readings that we

receive from this GPS system allow us to operate our drone below set minimums at all times.

14 CFR 91.151(a) Fuel requirements for flight in VFR conditions

This regulation states that no person may begin a flight in an airplane under day­VFR conditions

unless there is enough fuel to fly to the first point of intended landing and, after that, fly for an

additional 30 minutes. This regulation is intended to create a safe flying environment by creating

sufficient fuel reserves. Therefore, we do not request an exemption from this regulation but,

instead, request that the term “fuel” be changed to “battery power.” We also request that our

battery power reserve for our UAS operations be 30%.
Our UAS has capabilities that allow the PIC to monitor battery power levels as well as a return

to land feature that will engage when battery levels reach a critical level, therefore returning the

UAS automatically to the point of takeoff.

14 CFR Subpart E (91.401 – 91.417)

Bilal E Mustafa requests an exemption from the stringent maintenance regulations that are

designed to increase the safety of the flying environment by ensuring adequate inspections and

servicing of aircraft. We are requesting exemption from these regulations because we believe

that, due to the simplicity and the ease of repair, general and preventive maintenance can be

performed by the PIC.

The PIC is required to make a thorough preflight inspection before each operation. In the case

of a discovery of faulty equipment, most replacement and repair can simply be done on site as

long as repairs are of an airworthy manner. Major repair will still have to be performed by a

licensed repair facility which will be logged in the UAS records.

We believe that our comprehensive preflight inspection, the simplicity of the UAS itself, the

nature of the UAS’s operations, and the fact that no passengers are on board the aircraft make

our operations eligible for exemption from CFR Subpart E (91.401 – 91.417).