John Flower Productions 

607 W Main St. Ste. 201 

Louisville, KY 40202 

502-561-8000 

john@johnflowerproductions.com 

June 4, 2015 

U.S. Department of Transportation, Docket Operations 

West Building Ground Floor, Room W12-140 

1200 New Jersey Avenue, SE 

Re: Request for exemption under Section 333 from CFR Part 21, Subpart H; 14 CFR 

61.113(a) and (b); 14 CFR 91.109; 14 CFR 91.121; 14 CFR 91.151; (a); 14 CFR 

91.405(a); 14 CFR 91.407(a)(1); 14 CFR 91.409(a)(1); 14 CFR 91.409(a)(2); 14 CFR 

91.417(a) and (b) 

Dear Sir or Madam: 

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

(the Reform Act) and 14 CFR Part 11, John Flower Productions hereby applies for an 

exemption from the listed Federal Aviation Regulations (FARs) to allow commercial 

use of its Small Unmanned Aircraft Systems (SUASs), so long as such operations are 

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

by the FAA as required by Section 333. 

An exemption is being requested because (1) existing regulations will burden John 

Flower Productions, (2) John Flower Productions can provide a level of safety that is 

equal to or greater than those provided by existing rules, and (3) the request is in 

the public interest. The FAA's authority to issue exemptions from operating rules, 

and the Secretary's authority granted by Section 333 of P.L. 112-95, Special Rules 

for Certain Unmanned Aircraft Systems, provide an opportunity to authorize certain 

SUAS operations in the National Airspace System (NAS) prior to implementation of 

the SAUS rule. This incremental step will allow John Flower Productions to safely 

and legally enter into the NAS. 

As described in detail below, the requested exemption would permit John Flower 

Productions to operate SUASs under controlled conditions in airspace that is (1) 

limited, (2) predetermined, (3) controlled as to access, and ( 4) would provide safety 

enhancements to the already safe operations of those aircraft of similar size, weight, 

speed, and operating capability that have been granted entry in the NAS via the 

rules in Academy of Model Aeronautics (AMA) National Aircraft Safety Code. 

Approval of this exemption would thereby greatly enhance safety and fulfill the 

Secretary of Transportation's (the Secretary) responsibilities to " ... establish 

requirements for the safe operation of such aircraft systems in the national airspace 

system" per Section 333 (c) of the Reform Act. 
John Flower Productions is requesting exemption from the following regulations: 

14 CFR Part 21, Subpart H 

14 CFR 61.23 (a) 

14 CFR 61.113 (a) and (b) 

14 CFR 91.109 

14 CFR 91.121 

14 CFR 91.151 (a) 

14 CFR 91.405 (a) 

14 CFR 91.407 (a)(1) 

14 CFR 91.409 (a)(1) 

14 CFR 91.409 (a)(2) 

14 CFR 91.417 (a) and (b) 

This exemption application is expressly submitted to fulfill Congress' goal in passing 

Section 333 (a) through (c) of the Reform Act. This law directs to the Secretary to 

consider whether certain unmanned aircraft systems may operate safely in the NAS 

before completion ofthe rulemaking required under Section 332 of the Reform Act. 

In making this determination, the Secretary is required to determine which types of 

UASs do not create a hazard to users of the NAS, to the public, or pose a threat to 

national security. 

Section 333 of the Reform Act grants the Secretary authority to determine (1) if an 

unmanned aircraft system, as a result of its size, weight, speed, operating capability, 

proximity to airports and populated areas, and operation within visual line of sight 

(VLOS) does not create a hazard to users of the NAS or the public or pose a threat to 

national security, and (2) whether a certificate of waiver, certificate of 

authorization, or airworthiness certification under 49 USC 44 704 is required for the 

operation of civil (non-governmental) UASs. Therefore, ifthe Secretary determines 

that such vehicles "may operate safely in the national airspace system, the Secretary 

shall establish requirements for the safe operation of such aircraft in the national 

airspace system". (John Flower Productions has interpreted this provision to place 

the duty on the Secretary to not only process applications for exemptions under 

Section 3 3 3 of the Reform Act, but for the Secretary to craft conditions for safe 

operations of SUAS. if it should be determined that the conditions set forth herein do 

not fulfill the statutory requirements for approval. 

Corporate Overview 

John Flower Productions' SUASs are quadcopters, weighing 6.5 lbs. or fewer 

(including payload.) The SUASs have the capability to hover and move in the vertical 

and horizontal planes simultaneously. They will operate only in visual line of sight 

(VLOS) and will operate only in controlled and limited airspace. They are capable of 

operating at speeds of up to 43 knots, but will routinely be operated at much lower 

speeds. They will routinely be operated below 200 feet above ground level (AGL,) 

and never above 400 feet AGL. 
John Flower Productions' exemption request would permit its commercial 

operation of SUASs for aerial photography and videography in tightly controlled and 

limited airspace. Aerial photography and videography services will be offered to 

private events, commercial and personal realtors, home builders, golf courses, home 

contractors, advertising agencies, privately and publicly held companies, andjor 

home inspectors for use in, but not limited to, real estate marketing, safer 

inspections of homes, and general advertising and marketing purposes. Operations 

will always be conducted in areas that are free and clear of all people, except the 

pilot in command (PIC) and the PIC's assistant(s). Such operations will ensure that 

SUAS will "not create a hazard to users of the national airspace system or the 

public." (taken from Reform Act Section 333 (b)) 

Aircraft 

John Flower Productions operates Inspire 1 (http://www.dji.com/product!inspire1) SUASs manufactured by DJI, a well-known leader in quadcopter technology. DJI 

strives to bring new perspectives to aerial work and help companies accomplish 

feats safer, faster, and with greater efficiency. They have an unparalleled 

commitment to R&D, a culture of constant innovation, and a focus on transforming 

complex technology into easy-to-use devices. 

The standard Inspire 1 quadcopter package includes the Inspire 1 itself, camera, 

gimbel, propulsion system, flight control system, 5.8 GHz remote controller, and 2.4 

GHz communication system. The remote uses a 5.8 GHz frequency to prevent 

interference with the video/telemetry channel. This second channel allows for a 

constant connection with the Inspire 1 to monitor it via a smartphonejtablet that is 

attached to the remote controller. 

The Inspire 1 is about 17.2 inches x 17.7 inches x 11.9 inches in size. It has a 

maximum ascent speed of 16.4 feet per second, a maximum descent speed of 13.1 

feet per second, and a maximum flight speed of 43 knots. While operating within 

VLOS, the remote control has a range of approximately 2,600 feet. The total weight 

(including payload) is 6.4lbs. (http: //store.dji.com/product/inspire1 ?position+ 1 #spec). 

The Inspire 1 is equipped with a flight control system that provides incredible ease 

of use and stability. Pilots can control the Inspire 1's movements in many directions 

-including pitch (forward and backward), roll (left and right), elevator (up and 

down), and yaw (turn left and right). The flight control system can also provide 

intelligent orientation control, failsafe, battery level monitoring (and warnings), and 

show the aircraft's current heading, direction, and approximate distance from home 

on the on-screen radar. The built-in GPS system aids in stabilizing the aircraft and 

automatically and safely returns is back to its home point in any case where 

communication between the remote control and quadcopter are lost. 
The Inertial Measurement Unit (IMU) has a built-in inertial sensor and a barometric 

altimeter that measure both attitude (A TTl) and altitude. The IMU incorporates both 

a 6-axis gyroscope and an accelerometer to monitor minuscule changes in tilt and 

movement. This allows the aircraft to compensate and adjust immediately, holding 

its position at all times. 

The Inspire 1's compass reads geomagnetic information and assists the GPS to 

accurately calculate the position and height of the aircraft. The Inspire 1 also has a 

built-in Visual Positioning System (VPS) that allows takeoff and landing at the press 

of a button and keeps the Inspire 1 steady when GPS satellites cannot be required. 

The system combines visual data and sonar waves in a single unit, detecting both 

variance in patterns on the ground and current altitude. Information from the VPS is 

processed by a dedicated CPU chip that taken in feedback and outputs data in real 

time, and is intelligent enough to distinguish between objects and ground patterns. 

The data is given to the Inspire 1's flight controller, which in turns continues with 

the entire aircraft. 

The Inspire 1 has LED flight indicators beneath each of its four rotor arms. The LEDs 

on the arms as well as one on the battery illuminate to indicate the status of the 

flight control system and alert the PIC of any possible issues. Such highly advanced 

capabilities will ensure that the SUASs can be safely operated and "not create a 

hazard to users of the national space system or the public." (taken from the Reform 

Act Section 333 (b)) 

Equivalent Level of Safety 

In an effort to join the FAA in its mission to provide the safest, most efficient 

aerospace system in the world and to minimize the risk to the NAS or to persons and 

property on the ground, John Flower Productions agrees to be bound by the 

following limitations and conditions when conducting commercial operations under 

an FAA issued exemption: 

A For the purposes of ensuring SUASs will be operated within the standards 

that the FAA has allowed in the AMA National Model Aircraft Safety Code: 

1. SUASs will not be flown: 

i. In a careless or reckless manner 

ii. At a location where SUAS activities are prohibited 

2. SUAS pilots will: 

i. Yield the right of way to all human-carrying aircraft 

ii. See and avoid all aircraft and a spotter must be used when 

appropriate 

iii. Not fly higher than 400 feet AGL or within three (3) miles of an 

airport without notifying the airport operator 
iv. Not interfere with operations and traffic patterns at any 

airport, heliport, or seaplane base except where there is a 

mixed use agreement 

v. Not exceed a takeoff weight of 55 pounds (including payload) 

vi. Ensure the aircraft is identified by affixing the owner's contact 

information to the outside of the SUAS 

vii. Not operate SUAS while under the influence of alcohol of while 

using any drug that could affect the PIC's ability to safely 

control the model 

viii. Not operate SUASs carrying pyrotechnic devices that explode 

or burn, or any device which propels a projectile or drops any 

object that creates a hazard to persons or property 

3. SUASs will not be flown unless: 

i. The aircraft, control system, and pilot skills have successfully 

demonstrated all maneuvers intended or anticipated prior to 

the specific event 

ii. An inexperienced pilot is assisted by an experienced pilot 

4. All pilots shall avoid flying directly over unprotected people, vessels, 

vehicles or structures and shall avoid endangerment of life and property 

of others 

5. A successful radio equipment ground-range check in accordance with 

manufacturer's recommendations will be completed before the first flight 

of a new or repaired model aircraft 

6. SUASs must use the radio-control frequencies currently allowed by the 

Federal Communications Commission (FCC) 

7. SUASs will not knowingly operate within three (3) miles of any existing 

pre-existing flying site without a frequency-management agreement 

8. Excluding takeoff and landing, no SUASs may be flown closer than 25 feet 

to any individual, except for PIC and the PIC's assistant(s) located at the 

takeoff site 

9. Under no circumstances may a pilot or other person touch a SUAS in 

flight while it is still under power, except to divert it from striking an 

individual 

10. The PIC of the SUAS shall: 

i. Maintain control during the entire flight, maintaining visual 

contact without enhancement other than by corrective lenses 

prescribed for the pilot 

ii. Fly using the assistance of a camera or First-Person (FPV) only 

in accordance with the procedures outlined in AMA Document 

#550 

iii. Fly using the assistance of autopilot or stabilization system 

only in accordance with the procedures outlined in AMA 

Document #560 

11. The flying area must be clear of all utility wire or poles and an SUAV will 

not be flown closer than 50 feet to any above-ground electric utility lines 
12. The flying area must be clear before the engine is started, except for PIC 

and the PIC assistant(s) 

B. In addition to the above rules outlined by the AMA National Model Aircraft 

Safety Code and in an effort to enhance the safety offered by the already safe 

operations mentioned above, John Flower Productions also agrees to be 

bound by the following limitations and conditions: 

1. Flights will be operated within VLOS of the PIC 

2. Maximum total flight time for each operational flight will be 20 minutes. 

Flights will be terminated at 25% battery power reserve should that 

occur prior to the 20 minute limit 

3. The SUAS will only operate in tightly controlled and limited airspace 

4. A briefing will be conducted in regard to the planned SUAS operations 

prior to each flight. It will be mandatory that all personnel who will be 

performing duties within the boundaries of the safety perimeter be 

present for this briefing 

5. The PIC and PIC's assistant(s) will at all times be able to communicate by 

voice 

6. If the SUAS loses communications or loses its GS signal, the SUAS will 

have the capability to return to a pre-determined location within the 

security perimeter and safely land 

7. The SUAS will have the capability to abort a flight in case of unpredicted 

obstacles or emergencies 

8. All flights will be conducted with the written andjor oral permission of 

the owner/overseer of the property on which the flight is conducted 

9. The PIC and the PIC's assistant(s) will have been trained in operation of 

SUAS and received up-to-date information on the particular SUAS to be 

operated 

10. Flights will always be conducted in areas that are clear of all people, 

except for the PIC and the PIC's assistant(s) 

11. Flights will not be conducted outdoors in visual meteorological 

conditions (VMC) and never during severe weather conditions 

12. Flights will not occur in weather conditions that prevent the PIC from 

operating within visual line of sight at all times or in weather conditions 

that dramatically affect the SUAS's light (e.g. high winds) 

13. If an operation occurs in an area where people could inadvertently enter 

the area, an operational border will be established with traffic cones. If it 

is not feasible to use traffic cones due to interference with the 

photographyjvideography, the PIC's assistant(s) will be responsible for 

keeping a safe perimeter around the operation. The operation will cease 

immediately and be rescheduled if it is impossible to establish a safe 

perimeter around the operation 

14. The PIC will be responsible for logging all flights to ensure the 

comprehensive preventative maintenance plan can be followed, as 

prescribed in the "Preventative Maintenance" section below 

15. The SUAS will not be routinely operated in the proximity of any airports. 

In any cases where SUAS must be operated within three (3) miles of an 
airport, the airport operator will be notified before the operation 

commences 

The operation of SUASs weighing less than 7lbs., conducted in the strict conditions 

as outlined above, will provide an equivalent level of safety supporting the grant of 

exemptions requested herein, including exempting the applicant from the 

requirements of Part 21 and allowing commercial operations. 

These lightweight aircraft operate at slow speeds, close to the ground, and in a 

tightly controlled environment. As a result, they offer a much safer way to capture 

aerial photography and videography. Furthermore, the proposed operations 

represent a safety enhancement to the already safe operations that have been 

granted by the FAA for the establishment of the AMA National Model Aircraft Safety 

Code. 

Preflight Action Plan 

The PIC will follow a comprehensive pre-flight checklist to ensure that the SUAS is in 

a condition for safe flight. This plan will be improved as needed in order to ensure 

all known safety precautions an/or safety precautions suggested by the 

manufacturer are being accounted for. 

A Pre-flight Inspection 

1. Check that the remote control, Inspire 1 battery, range extender, 

and smartphonejtablet are all fully charged. 

2. Verify that the Inspire 1 battery is not swollen or damaged in any 

way. Clean the contact needles and pads if necessary. 

3. Turn the motor shafts with your fingers and verify they are 

smooth without excessive play or binding. 

4. Verify that the propellers are mounted correctly. Each propeller 

should spin all the way down onto the motor shaft and safety clips 

installed after the propeller. 

5. Run finger along the edge of the propeller blade to check for any 

rough edges. 

6. Flex both sides of the propellers' blades to check for hairline 

cracks where the blades connect in the center of the propeller. 

7. Verify that the landing gear is secure (not cracked/broken/loose.) 

8. Verify that the compass and compass cable are firmly attached to 

the landing gear. 

9. Verify that the Micro-SD card has been inserted and formatted. 

10. Verify that the damping absorbers are not broken and/or worn. 

11. Verify that the anti-drop pins are in place and locked. 

12. Remove the gimbal guard and camera lens cap. 

13. Verify that the camera is secure and clean. Inspect the camera 

ribbon cables for tears and/or signs of wear. 

14. Verify that the smartphonejtablet's GPS is enabled. 
15. Set the smartphonejtablet to do-not-disturb mode to prevent 

distractions while flying. 

16. Set the smartphonejtablet to forget any Wi-Fi networks in range 

in order to prevent the Wi-Fi connections from changing midflight. 

17. Verify that the smartphonejtablet's audio is on to ensure the low 

battery warning and other alarms can be heard. 

B. Power Up 

1. Verify that S1 and S2 are in the center position on the remote 

control. 

2. Power on the equipment. 

i. SUAS battery (blinking green indicates GPS lock and ready 

to fly.) 

ii. Remote control (solid green and chime indicate lock on 

SUAS and ready to fly.) 

3. Check the DJI Pilot app to ensure lock on 6+ sattelites and home 

point is marked (for use by the failsafe feature.) 

4. Calibrate the compass. 

5. Place the Inspire 1 on open, flat ground with the battery indicators 

facing toward the PIC at least 10 feet away. 

C. DJI Pilot App 

1. Connect the smartphonejtablet to the remote via USB 

2. Launch the app. 

3. Verify the number of satellites is 6+. 

4. Verify signal strength. 

5. Verify that the smartphonejtablet battery has a full charge. 

6. Verify that both the PIC's and the Inspire 1's location is the same 

before takeoff to ensure the home point has been accurately 

marked. 

7. Verify the location of the Inspire 1 in the "flight radar." If it is not in 

the correct position/ direction and/ or shows a distance of "N j A," it 

did not mark the home point. 

8. Use the "find my Inspire" feature to ensure the blue (home point 

location) and the red (Inspire 1location) dots are in the same 

location on the screen. 

D. Ready to Fly 

1. Verify that the remote antenna is perpendicular to the ground 

(pointing skyward.) 

2. Verify that the front, flat face of the range extender is pointed 

toward the Inspire 1. 

3. Verify that the rear LEDs are slowly blinking green and still 

connected to 6+ satellites. 

4. Start the Inspire 1's motors using the remote control. 

5. Verify the motors are functioning normally, and are not making 

any unusual noises, and are all spinning at the same speed. 
6. Verify that the area is clear of obstructions, people, power lines, 

etc. 

7. Take off and hover at about 6-8 feet above the takeoff point to 

verify that the Inspire1 has a solid GPS lock. If any abnormalities 

are noticed (drifting, flying in circles, etc) land immediately and 

repeat the "Pre-flight Inspection" and "Power Up" sequences. 

8. Verify the Inspire 1 holds a steady position while yawing 360 

degrees. 

9. Verify the Inspire 1 responds appropriately to all controls- yaw 

left/right, pitch forward/backward, and throttle up/down. 

Preventative Maintenance 

A comprehensive preventative maintenance plan will be followed in order to ensure 

the SUAS's software is up-to-date, the batteries are in good health, and the aircraft 

itself is always ready for safe flight. 

Pilot In Command (PIC) Qualifications 

The PIC does not hold an airman certificate or medical certification. Since the SUAS 

is similar in size, weight, speed, and operating capability as those currently allowed 

to be flown for hobby /recreation, holding the PIC to those same set of standards will 

allow for an equivalent level of safety. 

The PIC has years of electronics and computer systems experience. Since the SUAS is 

controlled by a highly advanced computer system and runs on software that must 

be configured, updated, and maintained, computer proficiency is a must to ensure 

the SUAS is ready to be safely operated in the NAS. 

It cannot be assumed that a commercial pilot, approved to operate a helicopter or 

fixed wing aircraft, has the skill or ability to safely operate an unmanned aerial 

vehicle, operating at 400 feet AGL or lower, within strictly controlled pre-approved 

and determined airspace. Since there are no standards for either private or 

commercial SUAS pilot certificated, knowledge of airspace regulations and dexterity 

in the control and operations of the SUAS acquired from actual operation of the 

aircraft will be the most important factors in establishing level of safety. With that in 

mind, John Flower Productions proposes that its PIC be required to do the following 

prior to the first commercial operation: 

1. Perform 20 flights or log 20 hours of flight time (the greater of the two) 

with the Inspire 1 

2. Successfully learn and demonstrate all flight maneuvers in the Inspire 1 

User Manual (http://download.djiinnovations.com/downloads!inspire 1/en!Inspire 1 User Manual v1.0 

en. pdf) 

3. Study and be familiar with all sections of the Inspire 1 User Manual 

Public Interest 
Granting this exemption would benefit the public as a whole. SUASs offer a strong 

equivalent level of safety, a reduction in environmental impacts, and are free from 

the harmful emissions associated with the manned aircraft that are currently used 

for commercial aerial photography and videography. Due to the size of the SUAS and 

the tightly controlled and limited airspace in which the SUAS would operate, 

approval of this application presents no risk to the public. 

Privacy 

Since the areas being photographed or filmed will be only upon receipt of written 

andfor oral consent by the property owner or overseer and clear of all people, 

except for the PIC and the PIC's assistant(s), approval of this application presents no 

risk to public privacy. 

National Security 

Due to the size of the SUAS and the tightly controlled and limited airspace in which 

the SUAS will operate, approval of this application presents no risk to national 

security. 

Requested Exemptions 

John Flower Productions requests exemption from the following regulations since it 

is not possible to fully comply with them, and since attempting to follow them for 

the purposes of operating SUAS would be a burden: 

Airworthiness Certificate 

14 CFR Part 21, Subpart H 

Subpart H establishes the procedural requirements for the issuance of 

airworthiness certificates as required by FAR 91.203(a)(1). Given the size and 

limited operating area associated with the aircraft to be utilized by John Flower 

Productions, an exemption from Part 21 Subpart H meets the requirements of an 

equivalent level of safety under Part 11 and Section 333 of the Reform Act. The 

Federal Aviation Act (49 USC 44701(f)) and Section 333 of the Reform Act both 

authorize the FAA to exempt aircraft from the requirement for an airworthiness 

certificate, upon consideration of the weight, size, speed, operational capability, and 

proximity to airports and populated areas of the particular SUAS. In all cases, an 

analysis of these criteria demonstrated that the SUAS operated without an 

airworthiness certificate, in the restricted environment and under the conditions 

proposed, will be at least safe, or safer, than a conventional aircraft operating with 

an airworthiness certificate without the restrictions and conditions proposed. 

Medical Certificates 

14 CFR 61.23(a) 

This regulation requires pilots of manned aircraft to hold a medical 

certificate. Since risks associated with the operation of the proposed SUAS as so 
diminished from the level of risk associated with any manned aircraft; the SUAS is of 

a size, weight, speed, and operational capabilities which make it much safer than 

any manned aircraft; since operations will occur in tightly controlled and limited 

airspace; and considering that all operations will be on approved property that is 

clear of people, obtaining and maintaining a medical certificate would not improve 

the safety of the operation. In the very rare case of mishap, the USAS being flown 

will pose significantly less of a threat then manned helicopters and fixed wing 

aircraft because the SUAS are a fraction of the size and weight and will be flown at a 

fraction of the speed, carry no flammable fuel, and carry no crew or passengers. 

Private pilot privileges and limitations: Pilot In Command 

14 CFR 61.113(a) and (b) 

These regulations limit private pilots to non-commercial operations. Because 

the SUAS will not carry a pilot or passengers; dues to the SUAS's size, weight, speed, 

and operational capabilities; and since operations will occur in tightly controlled 

and limited airspace, the proposed operations can achieve the equivalent level of 

safety of current operations that require a commercial pilot's license. Furthermore, 

since there are no standards for either private or commercial SUAS pilot certificates, 

knowledge of airspace regulations and dexterity in the control and operation of the 

SUAS acquired form actual operation of the aircraft will be the most important 

factors in establishing an equivalent level of safety. It cannot be assumed that a 

commercial pilot, approved to operate a manned helicopter or fixed wing aircraft, 

has the skill or ability to safely operate an unmanned aerial vehicle, operating at 400 

feet AGL or lower, within strictly controlled and pre-approved airspace. 

Flight Instruction 

14 CFR 91.109 

This regulation provides that no person may operate a civil aircraft (except a 

manned free balloon) that is being used for flight instruction unless that aircraft has 

fully functioning dual controls. 

SUAS and remotely piloted aircraft, by their design do not have fully 

functional dual controls. Flight control id accomplished through the use of a control 

box that communicates with the aircraft via radio communications. The FAA has 

approved exemptions for flight training without fully functional dual controls for a 

number of aircraft and for flight instruction in experimental aircraft. The equivalent 

level of safety will be provided by the fact that neither a pilot nor passengers will be 

carried in the aircraft and by the size and speed of the aircraft. 

Altimeter Settings 

14 CFR 91.121 

This regulation requires each person operating an aircraft to maintain 

cruising altitude by reference to an altimeter that is set" ... to the elevation of the 
departure airport or an appropriate altimeter setting available before departure." As 

the SUAS may not have a barometric altimeter, but instead a GPS altitude readout, 

an exemption may be needed. An equivalent level of safety will be achieved by the 

operator confirming the altitude of the launch site shown in the GPS altitude 

indicator before flight. 

Fuel Requirements for Flight in VFR Conditions 

14 CFR 91.151(a) 

This regulation prohibits an individual from beginning "a flight in an airplane 

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- (1) During the day, to fly after that for at least 30 minutes; 

or (2) At night, to fly after that for at least 45 minutes." 

The battery powering the SUAS provides approximately 20 minutes of 

powered flight. That makes it impossible to meet the 30-minute reserve 

requirement. Given the limitations on the SUAS's proposed flight area and the 

location of its proposed operations within a predetermined area, a longer time 

frame for flight in daylight or night VFR conditions is reasonable. 

An equivalent level of safety can be achieved by limiting flight to 20 minutes 

or 25% of battery (whichever occurs first). This restriction would be more than 

adequate to return the SUAS to its planned landing zone from anywhere in its 

limited operating area. 

Maintenance Inspections 

14 CFR 91.405(a); 14 CFR 91.407(a)(1); 14 CFR 91.409(a)(1); 14 CFR 91.409 

(a)(2); 14 CFR 91.417(a) and (b) 

These regulations require that an aircraft operator or owner "shall have the 

aircraft inspected as prescribed in subpart E of this part and shall between required 

inspections, except as provided in paragraph (c) of this section, have discrepancies 

repaired as prescribed in part 43 of this chapter. .. ," and others shall inspect or 

maintain the aircraft in compliance with Part 43. 

Given that these sections and Part 43 apply only to aircraft with an 

airworthiness certificate, these sections will not apply. Maintenance will be 

accomplished by the operator pursuant to the aforementioned Inspire 1 user 

manual. An equivalent level of safety will be achieved because these small SUAS are 

very limited in size, will carry a small payload, and operate only in restricted areas 

for limited periods of time. If mechanical issues arise, the SUAS will be operating 

from no higher than 400 feet AGL and can land immediately. As outlined in the 

aforementioned Pre-flight action plan, the operator will ensure that the SUAS is in 

working order prior to initiating flight and perform maintenance as required. 

Moreover, the operator is the person most familiar with the aircraft and best suited 
to maintain the aircraft in an airworthy condition to provide the equivalent level of 

safety. 

In accordance with 14 CFR Part 11, the following summary is provided for 

publication in the Federal Register: 

The applicant seeks and exemption from the following rules: CFR Part 21, 

Subpart H; 14 CFR 61.113(a) and (b); 14 CFR 91.109; 14 CFR 91.121; 14 CFR 

91.151; (a); 14 CFR 91.405(a); 14 CFR 91.407(a)(1); 14 CFR 91.409(a)(1); 14 CFR 

91.409(a)(2); 14 CFR 91.417(a) and (b) to commercially operate small unmanned 

aircraft systems (SSlbs. or less) in order to safely and legally capture aerial 

photography and videography for use by commercial and personal realtors, home 

builders, golf courses, home contractors, advertising agencies, privately and 

publicly held companies, andjor home inspectors. 

The operation of SUAS conducted in the strict conditions outlined above will 

provide an equivalent and/or greater level of safety supporting the grant of the 

exemptions requested herein, including exempting the applicant from the 

requirements of Part 21 and allowing commercial operations. These lightweight 

aircraft operate at slow speeds, close to the ground, and in a sterile environment, 

and as a result, are far safer than existing operations conducted with helicopters in 

close proximity to the ground, people, or other buildings in the vicinity. 

Given the small size of the SUAS involved, the slow speed at which they must be 

operated in order to capture photos and videos, and the restricted environment 

within which they will operate, the Inspire 1 demonstrates that it can be operated 

within an equivalent level of safety in which Congress envisioned that the FAA must, 

by exemption, allow commercial operations of SUAS to commence immediately. 

Also, due to the size of the SUAS and the restricted areas in which the relevant SUAS 

will operate, approval of this application presents no threat to national security. 

Given the clear direction in Section 333 of the Reform Act, the authority contained in 

the Federal Aviation Act, the strong equivalent level of safety surrounding the 

proposed operations, the significant public benefit- including enhanced safety, 

reduction in environmental impacts, no emissions, ability to legally obtain aerial 

photography and videography services- the grant of the requested exemptions is in 

the public interest. Accordingly, John Flower Productions respectfully requests that 

the FAA grant the requested exemption without delay. 

Satisfaction of the criteria provided in Section 3 3 3 of the Reform Act- size, weight, 

speed, operating capability, proximity to airports and populated areas, operation 

within the visual line of sight, public safety, and national security- providing more 

than adequate justification to grant John Flower Productions the requested 

exemption, allowing for commercial operations as described herewith. 

Sincerely, 
~ John Flower 

Owner, John Flower Productions