Submitted	by;	Nicholas	Gerfen

Date:	12/15/2015

Exemption	Applicants	Name:	Nicholas	B	Gerfen	

Office	phone:	616-951-3113

Fax:	844-596-6784

Email:	Nick@NorthGR.com

Website:	www.NorthGR.com

Address:	8254	E.	104th	St,	Howard	City,	MI	49329

Petition:

I	request	an	exemption	from	TITLE	14	OF	THE	CODE	OF	FEDERAL	REGULATIONS	SECTIONS:

14	C.F.R.	Part	21:	Airworthiness	Certificates	

14	CFR	61.101(e)(4) &	(5):	Recreational	pilot	privileges	and	limitations

14	C.F.R.	61.113(a)	&	(b):	Private	pilot	privileges	and	limitations:	Pilot	in	command	

14	C.F.R	91.7:	Civil	aircraft	airworthiness	

14	C.F.R.	91.9	(b)(2):	Civil	aircraft	flight	manual,	marking,	and	placard	requirements	

14	C.F.R.	91.119(c):	Minimum	safe	altitudes	

14	C.F.R.	91.121:	Altimeter	settings	

14	C.F.R.	91.151(a)(1):	Fuel	Requirements	for	flight	in	VFR	conditions	

14	C.F.R.	91.203(a)	and	(b):	Civil	aircraft:	Certifications	required	

14	C.F.R.	91.405(a):	Maintenance	Required

14	C.F.R.	91.407(a)(1):	Operation	after	maintenance,	preventive	maintenance,	rebuilding,	or	

alteration

14	C.F.R.	91.409(a)(1)	and	(2): Inspections

14	C.F.R.	91.417	(a)	and	(b):	Maintenance	records	

I	am	requesting	exemptions	from	the	above	regulations	in	order	to	operate	radio	controlled	

quad	copters	in	a	commercial	capacity.	My	operations	will	be	primarily	to	conduct	aerial	

photography	and	videography	for	homeowners,	realtors,	home	builders,	contractors,	and	home	

inspectors	for	real	estate	marketing	and	inspections	of	homes	for	sale.	In	addition	to	utilizing	

the	UAS	for	real	estate	purposes,	it	may	also	be	utilized	for	wedding	and	private	individual	

photography	and	agricultural	photography	and	videography.	In	addition	to	using	the	UAS	for	

commercial	endeavors,	I	will	also	offer	my	services	upon	request	and	with	proper	coordination	

to	any	official	search	and	rescue	or	emergency	services	organization	to	benefit	the	public.	

The	UAS	that	I	would	like	to	include	is	the	DJI	Inspire	1.	These	UASs	have	been	proven	reliable	

and	safe	flying	machines	managed	by	gyroscopically-stabilized	flight,	ground	detection,	GPSaided	navigation,	a	built-in	compass,	blinking	LED	lights.	The	DJI	Inspire	1	UAS	has	a	high	degree	
of	safety	and	utility	as	camera	platforms	because	self-stabilizing	autopilot	features.	The	DJI	

Inspire	1	also	has	the	ability	to	automatically	return	to	their	starting	point	in	the	event	of	a	

signal	loss,	or	if	a	return	home command	is	given.	This	particular	model	combines	state-of-theart,	proven	technology	with	high	quality	manufacturing	and	user-friendly	control	to	ensure	safe	

operation	and	easy	maintenance.	

This	request	will	benefit	the	public	by	helping	the	real	estate community	and	homeowners	

lower	costs	of	taking	aerial	photos.	It	will	benefit	the	environment	because	of	the	much	lower	

noise,	lower	energy	consumption	and	no	emissions	when	compared	to	using	a	light	plane	in	a	

similar	capacity.

This	exemption	will	not	adversely	affect	safety	due	to	the	user	flying	the	UAV	(myself)	abiding	

by	all	the	limitations	described	below:

1.	The	UA	will	not	be	operated	at	a	speed	exceeding	87	knots	or	the	max	speed	recommended	

by	the	aircraft	manufacturer.

2.	The	UA	will	not	be	operated	at	an	altitude	greater	than	400	feet	AGL

3.	The	UA	will	be	operated	within	visual	line	of	sight	at	all	times.

4.	All	operations	will	utilize	a	visual	observer.	The	observer	will	be	able	to	verbally	communicate	

with	the	pilot	at	all	times.	No	electronic	messaging	will	occur	during	flight	operations.	

5.	All	FAA	exemption	documents	and	operating	documents	will	be	accessible	to	the	operator	

during	UAS	operations.	Operating	documents	will	be	made	available	to	the	Administrator	or	

any	law	enforcement	official	upon	request.

6.	A	functional	test	flight	will	be	conducted	when	maintenance	or	alterations	are	accomplished	

on	critical	components.	Test	flights	will	be	conducted	at	least	500	feet	away	from	people	in	a	

manner	so	as	not	to	impose	an	undue	hazard	to	persons	and	property.

7.	I	will	ensure	the	UAS	is	in	a	condition	for	safe	flight.	I	will	conduct	preflight	inspections	before	

each	flight.	I	will	follow	all	manufacturer	guidelines	for	maintenance,	overhaul,	replacement,	

and	life	limit	requirements	for	the	aircraft	and	aircraft	components.	I	will	comply	with	all	

manufacturer	safety	bulletins.

8.	Flights	will	not	be	conducted	at	night.

9.	Flights	will	not	be	conducted	within	5NM	of	an	airport	unless	written	permission	is	obtained	

from	the	airport	management.

10.	The	UA	will	not	be	operated	less	than	500	feet	below	or	less	than	2000	feet	horizontally	

from	a	cloud	or	when	visibility	is	less	than	3	Statute	miles	from	the	PIC.

11.	The	UA	will	have	the	ability	to	return	to	a	pre-determined	point	if	radio	or	GPS	signal	is	lost.

12.	I	will	abort	the	flight	in	the	event	of	an	emergency	or	unpredicted	obstacle.	

13.	I	will	not	begin	a	flight	unless	the	batteries	have	enough	available	power	to	complete	the	

flight	with	at	least	a	5	minute	reserve.

14.	All	operations	will	be	conducted	in	accordance	with	an	ATO	issued	COA

15.	I	will	register	my	UAS	in	accordance	with	14	CFR	part	47.	I	will	apply	the	N	numbers	in	

accordance	with	14	CFR	part	45,	subpart	C.

16.	I	will	remain	clear	of	and	yield	right	of	way	to	all	manned	aviation	activities	at	all	times.
17.	All	flight	operations	will	be	conducted	at	least	500	feet	from	all	nonparticipating	persons,	

vessels,	vehicles,	and	structures	unless	nonparticipating	people	have	granted	permission,	or	are	

sufficiently	protected	from	the	UA	and	debris	in	the	event	of	an	accident.

18.	All	operations	will	be	conducted	over	private	or	controlled-access	property	with	permission	

from	the	property	owner/controller	or	authorized	representative.	

19.	Any	incident,	accident,	or	flight	operation	that	transgresses	the	lateral	or	vertical	

boundaries	of	the	operational	area	as	defined	by	the	applicable	COA	will	be	reported	to	the	

FAAs	UAS	integration	office	within	24	hours.	Accidents	will	be	reported	to	the	NTSB.

20.	To	ensure	safety	of	the	public	and	to	follow	FAA	guidelines,	all	non-essential	personnel	will	

be	removed	from	the	immediate	area	and	flight	path	of	UAS	operation.	Operation	will	be	

prohibited	in	highly	populated	areas	where	moderate/high	risk	to	the	public	such	as	major	

roadways,	stadiums,	concerts,	and	schools.

Thank	you	for	your	consideration	concerning	this	Petitioning	for	Exemption.

Sincerely,	

Nicholas	B	Gerfen