I (Brandon Vos of 2011 Leeland St, Houston, TX 77003) plan to operate a UAS, the DJI INSPIRE 1, which is 

comprised of an unmanned aircraft, Zenmuse X3 camera gimbal, and a transportable ground station. 

The INSPIRE is referred to as a quad-copter with a maximum gross weight of about 7 pounds. It is 

equipped with four rotors that are driven by electric motors powered by batteries. The UA has a 

maximum airspeed of 43 knots. It comes equipped with an X3 Camera model FC350. I will use the 

camera during operation of the UA over various areas in and around Houston, TX to photograph real 

estate for use in listing videos/ads for real estate agents at RE/MAX Inner Loop. 

I will abide by the following operational enhancements to ensure this exemption will provide a level of 

safety at least equal to existing rules: 

• I will only operate in reasonably safe environments that are strictly controlled, are away from 

power lines, elevated lights, airports and actively populated areas; and 

• I will conduct extensive preflight inspections and protocols, during which safety carries primary 

importance given the size, weight, speed, and limited operating area associated with the aircraft to 

be utilized, an exemption from 14 CFR part 21, Subpart H (Airworthiness Certificates) and § 91.203 

(a) and (b) (Certifications required), subject to certain conditions and limitations, is warranted and 

meets the requirements for an equivalent level of safety under 14 CFR part 11 and Section 333 of 

P.L. 112-95 (Section 333). 

I request an exemption from § 45.23 Marking of the aircraft because the UA will not have a cabin, 

cockpit or pilot station on which to mark certain words or phrases. Since two-inch lettering is difficult to 

place on such a small aircraft with dimensions smaller than the minimal lettering requirement I will mark 

the UAS in the largest possible lettering by placing the word “Experimental” on its fuselage as required 

by § 45.29(f) so that I or anyone assisting me as a spotter will see the markings. 

I request an exemption from §§ 91.405(a), 91.407(a)(1), 91.409(a)(2) and 91.417(a) and (b) Maintenance 

inspections may be required and should be granted since they only apply to aircraft with an 

airworthiness certificate. However, as a safety precaution I will perform a preflight inspection of the UAS 

before each flight as outlined in the UAS operation manuals and user guides. 

UAS Pilot in Command (PIC) 

I have trained for a private Pilot license with over 42 logged hours as PIC. I can achieve an equivalent 

level of safety as achieved by current regulations because the UAS does not carry any pilots or 

passengers. While helpful, a pilot’s license will not ensure remote control piloting skills. Furthermore, 

the risks of operating a UAS are far less than the risk levels inherent in the commercial activities outlined 

in 14 CFR part 61, et seq., thus I requests an exemption from § 61.113 Private Pilot Privileges and 

Limitations: Pilot in command. 

Regarding UAS operational training, I have flown numerous practice flights in remote areas as a hobbyist 

simulating flights for future commercial use to gain familiarization with the characteristics of the UAS’ 

performance in many different temperature and weather situations. I have completed all flights with no 

incidences or accidents. I also understand the aerodynamic characteristics of multi rotor aircraft to 

better understand the safe use of the UAS. 
For the safety purposes I will abide by the following additional operating conditions: 

• operate the UAS below 300 feet and within a radius distance of 800 feet from the controller to 

both aid in direct line of sight visual observation; 

• operate the UAS for 3-10 minutes per flight; 

• land the UAS prior to the manufacturer’s recommended minimum level of battery power; 

• operate the UAS only within visual line of sight (VLOS); 

• use the UAS’ global positioning system (GPS) flight safety feature whereby it hovers and then 

slowly lands if communication with the remote control pilot is lost; 

• conduct all operations under my own personal and flight safety protocols contained in the 

operating documents and will actively analyze flight data and other sources of information to 

constantly update and enhance my safety protocols; 

• Will NOT operate within 5 miles of airports. 

• Always obtain all necessary permissions prior to operation; and 

• Have procedures in place to abort flights in the event of safety breaches or potential danger. 

In addition to these steps, the INSPIRE 1 is also pre-equipped to not be operated in a no fly zone. DJI 

developed a flight limitation system to prohibit the UA from flying into the air space surrounding an 

airport. The graphic below shows the two airports in the greater Houston area that the INSPIRE will not 

operate in the orange circle surrounding their location.

No Fly Zone defined (DJI, 2015)
§ 91.7(a) prohibits the operation of an aircraft without an airworthiness certificate. Since there is 

currently no certificate applicable to his operation, this regulation is inapplicable. 

§ 91.9(b)(2) requires an aircraft flight manual in the aircraft, however since there are no pilots or 

passengers on board his aircraft and given its size, this regulation is inapplicable. 

A level of safety will be achieved by maintaining a safety/flight manual with the UAS ground station at all 

times while operating. 

§ 91.119 prescribes safe altitudes for the operation of civil aircraft, but that it allows helicopters to be 

operated at lower altitudes in certain conditions. I will not operate the UAS above the altitude of 300 

feet above ground level (AGL) and will also only operate in safe areas away from the public and traffic, 

thus “providing a level of safety at least equivalent to or below those in relation to minimum safe 

altitudes.” Given the size, weight, maneuverability, and speed of his UAS, an equivalent or higher level 

of safety will be achieved. 

§ 91.121 Altimeter settings is inapplicable since he UAS utilizes electronic GPS measuring displaying in 

AGL. 

I will always operate with a spotter, hereafter referred to as a visual observer (VO). I will brief the VO on 

conditions and limitations that the VO can perform the functions prescribed in the operating 

documents. The UA will never be operated beyond the actual visual capabilities of the VO, and the VO 

and PIC must have the ability to maintain visual line of sight (VLOS) with the UA at all times. It is the 

responsibility of the PIC to be aware of the VO’s visual limitations and limit operations of the UA to 

distances within the visual capabilities of both the PIC and VO. Moreover, the VO will not be operating 

the aircraft. Additionally all persons not essential to flight operations (nonparticipating persons) will 

remain at appropriate distances or indoors during flights. If at any time the safety of persons is in 

question the flight will be terminated until such time the area of operation is made safe. 

Aerial videography for real estate marketing has been around for a long time through manned fixed 

wing aircraft and helicopters, but for small business owners, its expense has been cost-prohibitive. 

Granting this exemption would allow people to provide this service at a much lower cost. Further, the 

small UAS will pose no threat to the public given its small size and lack of combustible fuel when 

compared to larger manned aircraft. Also the operation of the UAS will minimize ecological damage and 

promote economic growth by providing information to companies/people looking to relocate or build in 

the Houston, TX metro area.