August 26, 2015

Exemption No. 12625

Regulatory Docket No. FAA−2015−2446

Mr. Gary Buzel

8211 Vincetta Drive

Apartment 16

La Mesa, CA 91942−2440

Dear Mr. Buzel:

This letter is to inform you that we have granted your request for exemption. It transmits our 

decision, explains its basis, and gives you the conditions and limitations of the exemption, 

including the date it ends.

By letter dated June 2, 2015, you petitioned the Federal Aviation Administration (FAA) for an 

exemption. You requested to operate an unmanned aircraft system (UAS) to conduct aerial

photography, videography, and search and rescue operations.

See Appendix A for the petition submitted to the FAA describing the proposed operations and 

the regulations that the petitioner seeks an exemption.

The FAA has determined that good cause exists for not publishing a summary of the petition 

in the Federal Register because the requested exemption would not set a precedent, and any 

delay in acting on this petition would be detrimental to the petitioner.

Airworthiness Certification

The UAS proposed by the petitioner is a DJI Inspire 1.
2

The petitioner requested relief from 14 CFR part 21, Certification procedures for products 

and parts, Subpart H—Airworthiness Certificates. In accordance with the statutory criteria 

provided in Section 333 of Public Law 112−95 in reference to 49 U.S.C. § 44704, and in 

consideration of the size, weight, speed, and limited operating area associated with the 

aircraft and its operation, the Secretary of Transportation has determined that this aircraft 

meets the conditions of Section 333. Therefore, the FAA finds that the requested relief from 

14 CFR part 21, Certification procedures for products and parts, Subpart H—Airworthiness 

Certificates, and any associated noise certification and testing requirements of part 36, is 

not necessary.

The Basis for Our Decision

You have requested to use a UAS for aerial data collection1. The FAA has issued grants of 

exemption in circumstances similar in all material respects to those presented in your petition. 

In Grants of Exemption Nos. 11062 to Astraeus Aerial (see Docket No. FAA−2014−0352), 

11109 to Clayco, Inc. (see Docket No. FAA−2014−0507), 11112 to VDOS Global, LLC (see

Docket No. FAA−2014−0382), and 11213 to Aeryon Labs, Inc. (see Docket No. 

FAA−2014−0642), the FAA found that the enhanced safety achieved using an unmanned 

aircraft (UA) with the specifications described by the petitioner and carrying no passengers or 

crew, rather than a manned aircraft of significantly greater proportions, carrying crew in 

addition to flammable fuel, gives the FAA good cause to find that the UAS operation enabled 

by this exemption is in the public interest.

Having reviewed your reasons for requesting an exemption, I find that—

• They are similar in all material respects to relief previously requested in Grant of 

Exemption Nos. 11062, 11109, 11112, and 11213;

• The reasons stated by the FAA for granting Exemption Nos. 11062, 11109, 11112, and 

11213 also apply to the situation you present; and 

• A grant of exemption is in the public interest.

Our Decision

In consideration of the foregoing, I find that a grant of exemption is in the public interest. 

Therefore, pursuant to the authority contained in 49 U.S.C. 106(f), 40113, and 44701, 

delegated to me by the Administrator, Mr. Gary Buzel is granted an exemption from 14 CFR 

§§ 61.23(a) and (c), 61.101(e)(4) and (5), 61.113(a), 61.315(a), 91.7(a), 91.119(c), 91.121, 

91.151(a)(1), 91.405(a), 91.407(a)(1), 91.409(a)(1) and (2), and 91.417(a) and (b), to the 

 

1 Aerial data collection includes any remote sensing and measuring by an instrument(s) aboard the UA. 

Examples include imagery (photography, video, infrared, etc.), electronic measurement (precision surveying, RF 

analysis, etc.), chemical measurement (particulate measurement, etc.), or any other gathering of data by 

instruments aboard the UA.
3

extent necessary to allow the petitioner to operate a UAS to perform aerial data collection. 

This exemption is subject to the conditions and limitations listed below.

Conditions and Limitations

In this grant of exemption, Mr. Gary Buzel is hereafter referred to as the operator.

Failure to comply with any of the conditions and limitations of this grant of exemption will be 

grounds for the immediate suspension or rescission of this exemption.

1. Operations authorized by this grant of exemption are limited to the DJI Inspire 1 when 

weighing less than 55 pounds including payload. Proposed operations of any other 

aircraft will require a new petition or a petition to amend this exemption.

2. Operations for the purpose of closed-set motion picture and television filming are 

not permitted. 

3. The UA may not be operated at a speed exceeding 87 knots (100 miles per hour). The 

exemption holder may use either groundspeed or calibrated airspeed to determine 

compliance with the 87 knot speed restriction. In no case will the UA be operated at 

airspeeds greater than the maximum UA operating airspeed recommended by the 

aircraft manufacturer.

4. The UA must be operated at an altitude of no more than 400 feet above ground level 

(AGL). Altitude must be reported in feet AGL.

5. The UA must be operated within visual line of sight (VLOS) of the PIC at all times. 

This requires the PIC to be able to use human vision unaided by any device other than 

corrective lenses, as specified on the PIC’s FAA-issued airman medical certificate or

U.S. driver’s license.

6. All operations must utilize a visual observer (VO). The UA must be operated within 

the visual line of sight (VLOS) of the PIC and VO at all times. The VO may be used 

to satisfy the VLOS requirement as long as the PIC always maintains VLOS 

capability. The VO and PIC must be able to communicate verbally at all times; 

electronic messaging or texting is not permitted during flight operations. The PIC 

must be designated before the flight and cannot transfer his or her designation for the 

duration of the flight. The PIC must ensure that the VO can perform the duties 

required of the VO.

7. This exemption and all documents needed to operate the UAS and conduct its 

operations in accordance with the conditions and limitations stated in this grant of 

exemption, are hereinafter referred to as the operating documents. The operating 

documents must be accessible during UAS operations and made available to the 
4

Administrator upon request. If a discrepancy exists between the conditions and 

limitations in this exemption and the procedures outlined in the operating documents, 

the conditions and limitations herein take precedence and must be followed. 

Otherwise, the operator must follow the procedures as outlined in its operating 

documents. The operator may update or revise its operating documents. It is the 

operator’s responsibility to track such revisions and present updated and revised 

documents to the Administrator or any law enforcement official upon request. The 

operator must also present updated and revised documents if it petitions for extension 

or amendment to this grant of exemption. If the operator determines that any update 

or revision would affect the basis upon which the FAA granted this exemption, then 

the operator must petition for an amendment to its grant of exemption. The FAA’s 

UAS Integration Office (AFS−80) may be contacted if questions arise regarding 

updates or revisions to the operating documents.

8. Any UAS that has undergone maintenance or alterations that affect the UAS operation 

or flight characteristics, e.g., replacement of a flight critical component, must undergo 

a functional test flight prior to conducting further operations under this exemption. 

Functional test flights may only be conducted by a PIC with a VO and must remain at 

least 500 feet from other people. The functional test flight must be conducted in such 

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

9. The operator is responsible for maintaining and inspecting the UAS to ensure that it is 

in a condition for safe operation.

10. Prior to each flight, the PIC must conduct a pre-flight inspection and determine the 

UAS is in a condition for safe flight. The pre-flight inspection must account for all 

potential discrepancies, e.g., inoperable components, items, or equipment. If the 

inspection reveals a condition that affects the safe operation of the UAS, the aircraft is 

prohibited from operating until the necessary maintenance has been performed and the 

UAS is found to be in a condition for safe flight.

11. The operator must follow the UAS manufacturer’s maintenance, overhaul, 

replacement, inspection, and life limit requirements for the aircraft and 

aircraft components.

12. Each UAS operated under this exemption must comply with all manufacturer 

safety bulletins.

13. Under this grant of exemption, a PIC must hold either an airline transport, 

commercial, private, recreational, or sport pilot certificate. The PIC must also hold a 

current FAA airman medical certificate or a valid U.S. driver’s license issued by a 

state, the District of Columbia, Puerto Rico, a territory, a possession, or the Federal 

government. The PIC must also meet the flight review requirements specified in 

14 CFR § 61.56 in an aircraft in which the PIC is rated on his or her pilot certificate.
5

14. The operator may not permit any PIC to operate unless the PIC demonstrates the 

ability to safely operate the UAS in a manner consistent with how the UAS will be 

operated under this exemption, including evasive and emergency maneuvers and 

maintaining appropriate distances from persons, vessels, vehicles and structures. PIC 

qualification flight hours and currency must be logged in a manner consistent with 

14 CFR § 61.51(b). Flights for the purposes of training the operator’s PICs and VOs 

(training, proficiency, and experience-building) and determining the PIC’s ability to 

safely operate the UAS in a manner consistent with how the UAS will be operated 

under this exemption are permitted under the terms of this exemption. However, 

training operations may only be conducted during dedicated training sessions. During 

training, proficiency, and experience-building flights, all persons not essential for 

flight operations are considered nonparticipants, and the PIC must operate the UA 

with appropriate distance from nonparticipants in accordance with 14 CFR § 91.119.

15. UAS operations may not be conducted during night, as defined in 14 CFR § 1.1. All 

operations must be conducted under visual meteorological conditions (VMC). Flights 

under special visual flight rules (SVFR) are not authorized.

16. The UA may not operate within 5 nautical miles of an airport reference point (ARP) as 

denoted in the current FAA Airport/Facility Directory (AFD) or for airports not 

denoted with an ARP, the center of the airport symbol as denoted on the current 

FAA-published aeronautical chart, unless a letter of agreement with that airport’s 

management is obtained or otherwise permitted by a COA issued to the exemption 

holder. The letter of agreement with the airport management must be made available 

to the Administrator or any law enforcement official upon request.

17. 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.

18. If the UAS loses communications or loses its GPS signal, the UA must return to a 

pre-determined location within the private or controlled-access property.

19. The PIC must abort the flight in the event of unpredicted obstacles or emergencies.

20. The PIC is prohibited from beginning a flight unless (considering wind and forecast 

weather conditions) there is enough available power for the UA to conduct the 

intended operation and to operate after that for at least five minutes or with the reserve 

power recommended by the manufacturer if greater.

21. Air Traffic Organization (ATO) Certificate of Waiver or Authorization (COA). All 

operations shall be conducted in accordance with an ATO-issued COA. The 

exemption holder may apply for a new or amended COA if it intends to conduct 

operations that cannot be conducted under the terms of the attached COA.
6

22. All aircraft operated in accordance with this exemption must be identified by serial 

number, registered in accordance with 14 CFR part 47, and have identification 

(N−Number) markings in accordance with 14 CFR part 45, Subpart C. Markings must 

be as large as practicable.

23. Documents used by the operator to ensure the safe operation and flight of the UAS and 

any documents required under 14 CFR §§ 91.9 and 91.203 must be available to the 

PIC at the Ground Control Station of the UAS any time the aircraft is operating. 

These documents must be made available to the Administrator or any law enforcement 

official upon request.

24. The UA must remain clear and give way to all manned aviation operations and 

activities at all times. 

25. The UAS may not be operated by the PIC from any moving device or vehicle. 

26. All Flight operations must be conducted at least 500 feet from all nonparticipating 

persons, vessels, vehicles, and structures unless:

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

from the UA and/or debris in the event of an accident. The operator must ensure 

that nonparticipating persons remain under such protection. If a situation arises 

where nonparticipating persons leave such protection and are within 500 feet of 

the UA, flight operations must cease immediately in a manner ensuring the safety 

of nonparticipating persons; and

b. The owner/controller of any vessels, vehicles or structures has granted permission 

for operating closer to those objects and the PIC has made a safety assessment of 

the risk of operating closer to those objects and determined that it does not 

present an undue hazard.

The PIC, VO, operator trainees or essential persons are not considered 

nonparticipating persons under this exemption.

27. All operations shall be conducted over private or controlled-access property with 

permission from the property owner/controller or authorized representative. 

Permission from property owner/controller or authorized representative will be 

obtained for each flight to be conducted.

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

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

to the FAA's UAS Integration Office (AFS−80) within 24 hours. Accidents must be 

reported to the National Transportation Safety Board (NTSB) per instructions 

contained on the NTSB Web site: www.ntsb.gov.
7

If this exemption permits operations for the purpose of closed-set motion picture and 

television filming and production, the following additional conditions and limitations apply.

29. The operator must have a motion picture and television operations manual (MPTOM) 

as documented in this grant of exemption.

30. At least 3 days before aerial filming, the operator of the UAS affected by this 

exemption must submit a written Plan of Activities to the local Flight Standards 

District Office (FSDO) with jurisdiction over the area of proposed filming. The 3-day 

notification may be waived with the concurrence of the FSDO. The plan of activities 

must include at least the following:

a. Dates and times for all flights;

b. Name and phone number of the operator for the UAS aerial filming conducted 

under this grant of exemption;

c. Name and phone number of the person responsible for the on-scene operation of 

the UAS;

d. Make, model, and serial or N−Number of UAS to be used;

e. Name and certificate number of UAS PICs involved in the aerial filming;

f. A statement that the operator has obtained permission from property owners 

and/or local officials to conduct the filming production event; the list of those 

who gave permission must be made available to the inspector upon request;

g. Signature of exemption holder or representative; and

h. A description of the flight activity, including maps or diagrams of any area, city, 

town, county, and/or state over which filming will be conducted and the altitudes 

essential to accomplish the operation.

31. Flight operations may be conducted closer than 500 feet from participating persons 

consenting to be involved and necessary for the filming production, as specified in the 

exemption holder’s MPTOM.

Unless otherwise specified in this grant of exemption, the UAS, the UAS PIC, and the UAS 

operations must comply with all applicable parts of 14 CFR including, but not limited to, 

parts 45, 47, 61, and 91.
8

This exemption terminates on August 31, 2017, unless sooner superseded or rescinded.

Sincerely,

/s/

John S. Duncan

Director, Flight Standards Service

Enclosures
June	2,	2015

FROM: Gary	Buzel

8211	Vincetta	Dr.,	Apt.	16

La	Mesa,	CA		91942-2440

858-361-9711

gbuzel@gmail.com

TO: U.S.	Department	of	Transportation

Docket	Management	System

1200	New	Jersey	Ave.,	S.E.

Washington,	DC		20590

Subject:	 Exemption	Request	under	section	333	of	the	FAA	Reform	Act and	Part	

11	of	the	Federal	Aviation	Regulations	contained	in	14	CFR:	45.23(b),	91.103,	

91.109,	91.119,	91.121,	 91.151(a),	91.203(a),	91.7(a),	91.9(b)(2),		91.405(a),	

91.407(a)(1),	91.409(a)(2),	91.417(a)(b).

To	whom	it	may	concern:

I	am	writing	the	exemption	request	on	my	own	behalf,	acting	as	pro	pur -

without	counsel.		

Pursuant	to	Section	333	of	the	FAA	Modernization	and	Reform	Act	of	2012	

(the	“Reform	Act”)	and	C.F.R.	Part	11,	Gary	Buzel	(petitioner,	applicant,	operator,	

operational	control),	owner	and	operator	of	a	Small	Unmanned	Aircraft	System	

(sUAS)	seek	exemptions	from	Federal	Aviation	Regulations	detailed	herein	for	the	

operation	of	lightweight	aerial	imaging	equipment	for	the	purposes of	aerial	

photography,	videography,	and	for search	and	rescue	operations.	
The	reason	this	applicant	is	requesting	exemptions	from	the	listed	Federal	

Aviation	Regulations	is	to	allow	for	commercial	operation	of	a	sUA	to	collect	aerial	

images/video for	real	estate,	weddings,	newsgathering,	and	search	and	rescue

events	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	333.1.

The	Petitioner/Operator:

The	petitioner	– Gary	Buzel	has	been	a	licensed	pilot	since	1995 currently	

holding	an	Airline	Transport	Pilot	Certificate	(#3003234)	for	Multi	Engine	Land	and	

CE-500	(Cessna	Citation	II	Jet)	type,	and	Commercial	Pilot	Privileges	for	Single	

Engine	Land	and	Sea	Airplane.		The	petitioner	also	holds	a	Certified	Flight	Instructor	

Certificate	(#3003234	CFI)	for	Airplane	Single/Multi	Engine	and Instrument	

Airplane.		The	petitioner	holds	a	Ground	Instructor	for	Instrument	and	Advanced.		

The	petitioner	has	3990	hours	total	time,	3872 in	airplanes,	18	in	rotorcraft,	and	has	

been	a	past aviation	safety	counselor	with	the	Bradley International (Windsor	

Locks,	CT	KBDL)	flight	standards	district	office	(FSDO)	under	the	leadership	of	FAA	

Aviation	Safety/Operations	Inspector	James	Adams.			

The	petitioner	has	5	years	experience	in	aerial	photography	from	Cessna	

172,	182	and	PA-28-181	manned	aircraft platform.		The	petitioner	has	been	flying	

model	aircraft	since	he	was	13,	and	has	been	flying	sUAS	“quadcopters”	for	2	years	

as	a	hobbyist	and	has approximately	200	hours	of	total	sUAS	time.			

The	petitioner	has	instilled	safety	protocols	derived	from	his	training	as	a	

manned-aircraft	professional	pilot	in	combination	with	working	with	interests	on	

the	ground	to avoid	and	prevent	an	sUAS	being	a	public	hazard both	in	the	air	and	

on	the	ground.			The	petitioner	is	available	to	offer	assistance	to	the	FAA	in	

developing	operational	and	safety	protocols	for	sUAS’s to	be	integrated	into	the	

National	Airspace	System	(NAS).		The	petitioner	believes	that	his	exemption,	if	

granted,	would	provide	the	FAA	with	an	analytical,	expanded	and	diverse	sUAS	
experience	to	help	establish	the	necessary	requirements	and	protocols	for	the	safe	

operation	of	such	aircraft	systems	in	numerous	applications	within	the	NAS.	

Aircraft

The	petitioner	will	operate	a	sUAS	made	by	manufacturer	DJI,	model	Inspire	

1/T600.		Serial	number	W13DCA16020308,	FAA	registered	under	tail	number	

N774GB.		The	Inspire	1/T600	description	and	equipment	is	as	follows:

• The	Inspire	1/T600	is	a	sUAS	quadcopter	made	by	DJI	that	has	a	fixed	

camera	gimbal	attached	to	a	4K	camera	which	sits	below	the	aircraft	

fuselage.		This	camera	allows	the	operator	on	the	ground	to see	a	720P	high	

resolution	a	view	from	the	aircraft	that	can	be	rotated	a	360	degree	angle	inflight.		

• Max	takeoff	weight	is	6.47	pounds

• Downlink	telemetry	to	allow	the	operator	to	see	onboard	information	

relating	to	safe	operations	of	flight	including	but	not	limited	to; battery	

percentage	remaining,	overall	status	of	flight	systems,	GPS	location	for	

position	hold,	auto	return	to	home,	and	operational	failsafes.

• The	Inspire	1/T600	is	limited	by	its	software	to	a	maximum	ascent	rate	of	

984	feet	per	minute and	an	altitude	of	400	feet.		Its	maximum	forward	speed	

is	49	statue	miles	per	hour	or	37	knots.

• The	Inspire	1/T600	is	powered	by	a	5700	mah, 22	volt	battery,	providing	22	

minutes	of	flight time	under	standard	conditions per	specifications.		The	

aircraft	alerts	the	operator	with	visual	and	audible	warnings	at	35%	of	

battery	remaining.		The	aircraft	will	not	be	operated	in	the	air	with	less	than	

35%	of	battery	remaining,	and	0-35%	is	kept	as	emergency	reserve	to	power	

the	sUAS	to	a	safe	landing	location	in	the	event	of	an	emergency.		

Ground	Based	Control	and	Communications	System
• The	Inspire	1/T600	is	controlled	using	a	DJI	manufactured	transmitter,	

operating	on	FCC	authorized frequencies	of	the	2.4	GHz	band (2.4	– 2.483	

GHz)		See	Manual	page	57	for	radio	transmitter	specifications.			The	

transmitter	has	been	approved	by	the	Federal	Communications	Commission	

and	bears	approval	logo	on	the	transmitter.	

• The	above	listed	transmitter	has	a	lithium	polymer	battery	powering	the	unit	

for	approximately	4	hours	time	between	charges	according	to	DJI	

specifications.

• The	Inspire	1/T600’s	controller	will	be	utilized	by	a	single	operator,	but	will	

require	a	visual	observer	when	necessary

• The	Inspire	1/T600	when	coupled	with	an	Apple	iPad	Air	2	provides	the	

operator	with	a	moving	map	display	showing	exact	aircraft	position,	and	HD	

video	from	the	aircraft	camera.		Also	the	controller	has	it’s	own	GPS	receiver	

establishing	a	“home	point”	on	each	take	off,	therefore	calibrating	the	aircraft	

to	return	to	this	takeoff	point	in	the	event	of	a	control	link	signal	loss	or	

interference.		

• Gary	Buzel	– the	petitioner/operator	while	engaged	in	sUAS	flight	under	this	

exemption	will	be	carrying	a	Yaesu FTA-550,	Air	Band	communications	radio	

serial	number	#4N100614.		The	radio	is	capable	of	transmitting	and	

receiving	radio	signals	on	the	IACO	radio	aviation	band	of	118.000	to	

136.975	MHz.		The	radio	has	a	transmit	power	output	of	5	watts	AM	PEP.		

While	the	sUAS	is	in	flight	in	Class	G	and	E	airspace	the	operator,	and/or	

observer	will	monitor	“guard”	frequency	of	121.500	MHz.		If	operations	are	

in	controlled	airspace	Classes	B,C,D,E,	the	operator	will	monitor	and	

communicate	directly	if	needed	with	the	ATC facility	in	charge	of	that	
respective	airspace.		Communications	with	ATC	will	be	standard	aviation	

communication	etiquette/procedures utilizing	the	sUAS’s	“N”	number	issued	

by	the	FAA	registration	branch	to	identify	this	aircraft	to	ATC.		Having	real	

time radio	communications	with ATC	and	nearby	aircraft	we	believe adds	a	

significant	margin	of	safety	to	our	operation	and	the	operations	of	other	

manned	aircraft	in	the	NAS.		The	operator	also	holds	an	FCC	restricted	radio	

telephone	operator	permit.

• Gary	Buzel	will	be	the	sole	operator	of	the	sUAS	for	each	flight,	and	when	

necessary	will	partner	with	a	Visual	Observer	to	assist	in	keeping	in	sight	the	

sUAS	at	all	times.		The	Visual	Observer	will	assist	the	operator	with	obstacle	

clearance,	people	separation	and	navigation	over	terrain.		

Operator’s - Safety	Plan

• Compliance	with	all	FAA,	state,	and	local	municipal	regulations.

• Altitude	of	operations	less	than	400	Feet	AGL,	although	most	operations	will	

be	at	“tree	line	level”	or	under	200	feet.

• Preflight	aircraft	inspections conducted	prior	to	each	flight	per	DJI	

Inspire1/T600	operators	guide.

• Postflight	aircraft	inspection	conducted	to	each	flight	per	DJI	Inspire1/T600	

operators	guide

• Operator	will	conduct	preflight	planning,	to	include	a	weather	briefing via	

DUATS	or	FSS,	NOTAM/TFR/MOA checks,	battery	- power	management	

calculations,	and	any	COA	requests	or	ATC/Airport	management	

notifications done	before	flight.		

• No	operations	directly	over	people	or	crowds.
• Operations	will	be	only	during	daylight	times,	in	VMC	conditions,	weather	

minimums	include	500	feet	below,	2,000	feet	horizontal	from	clouds,	and	

minimum	3	statue	miles	visibility.			No	Special	VFR	or	IFR	flights	will	be	

conducted.		

• Any	inflight	emergencies	will	result	in	an	immediate	landing.		There	will	be	

no	“land	when	practicable”	operations.		

• The	Inspire	1/T600	will	be	maintained	per	DJI	instructions,	and	will	follow	

manufacturer	safety	bulletins.		

• If	operating	near	an	airport	or	in	Class	B,C,D	airspace	under	a	COA,	operator	

will	notify	ATC	via	telephone	prior	to	takeoff	and	notify	via	radio	utilizing	the	

sUAS’s	tail	number.		If	radio	or	telephone	communications	cannot	be	

established	with	ATC/Tower,	the	flight	will	not	commence.		

• When	operating	inflight,	operator	will	monitor	“GUARD”	frequency of	121.5	

MHZ	and	comply	with	any	emergency	requests	if	received.		

• Operator	will	grant	right	of	way	to	ALL other	manned	operations	and	

activities	at	all	times.

Lastly,	the	petitioner’s	safety	plan	is	to	operate	the	aircraft	within	the	limitations	

provided by	DJI	– The	manufacturer.		This	is	to	include,	weight	and	balance,	speed	

limitations,	and	altitude	limitations.

Statutory	Authority

Section	333,	titled	“Special	Rules	for	Certain	Unmanned	Aircraft	Systems,”	

provides	a	mechanism	for	seeking	expedited	FAA	authorization	of	safe	civil	sUAS	

operations	in	the	National	Airspace	System	(NAS).		Section	333(a)	states	that	the	

FAA	“shall	determine	if	certain	unmanned	aircraft	systems	may	operate	safely	in	the	

national	airspace	system	before	completion	of	the	comprehensive	plan	and	

rulemaking	required	by	section	332(b)(1)	of	this	Act	or	the	guidance	required	by	

section	334	of	this	Act.”		In	Section	332(b)(1),	Congress	made	it	clear	that	Section	

333	provides	a	mechanism	for	“expedited	operational	authorization.”		The	FAA	has	
committed	to	complying	with	this	mandate	by	granting	several	petitions	almost	

identical	to	the	one	at	hand.		See,	e.g.	Exemption	No.	11062,	Regulatory	Docket	No.	

FAA-2014-0352	(granting	regulatory	exemptions	to	Astreus	Aerial	for	operation	of	

unmanned	aircraft	systems	for	the	purpose	of	filming	for	the	motion	picture	and	

television	industry	and	aerial	videography).

Section	333(b)	identifies	several	factors	that	the	FAA	should	consider	in	

determining	whether	commercial	sUAS operations	should	be	approved.		These	

include	sUAS	that,	“as	a	result	of	their	size,	weight,	and	speed,	operational	capability,	

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

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

security.”		See	section	333(b).

In	addition	to	the	specific	authority	conferred	by	Section	333,	the	FAA	

Administrator	has	general	authority	to	grant	exemptions	from	the	FAA’s	safety	

regulations	and	minimum	standards	when	the	Administrator	decides	a	requested	

exemption	is	in	the	public	interest.		See	U.S.C.	§ 44701(f)

Requested	Exemptions

14	CFR	Part	21 and	14	CFR	91.203(a):		Airworthiness	Certificates

The	petitioner	seeks	exemptions	to	apply	for	and	maintain	airworthiness	

certification	for	our	sUAS.		Model	and	serial	numbers	of	our	sUAS	is	provided	above.		

The	petitioner	will	keep	his	sUAS	in a	safe,	reliable,	and	airworthy	condition,	but	it	

may	not	meet	all	standards	set	forth by	part	91.203.		Petitioner/operator	will	

assume	all	responsibility	for	determining	that	the	sUAS	is	in	a	condition	safe	for	

flight,	as	well	as	a	condition	that	will	not	harm	other	people	or	property.		This	will	

be	facilitated	by	operator	using	specific	guidelines	from	the	manufacturer,	DJI,	as	

well	as	following	any	guidance	set	for	routine	maintenance.			
14	CFR	45.23(b):	 Display	of	Marks;	general

Under	this	part	it	is	required that	each	operator	must	display	on	that	aircraft	marks	

consisting	of	the	Roman	Capital “N”	followed	by	the	registration	number	of	the	

aircraft.		And	near	the	entrance	to	the	cabin or	canopy	etc., in	letters	between	2-6	

inches	in	size	the	word	“experimental.”..		

The	Inspire	1/T600	sUAS	is	physically	too	small	to	place	“N” numbers	and	

“experimental” identifiers of	this	size specified	in	this	section.		We	can	comply	

completely	with	an	“N”	number	and	the	“experimental”	identifier	but	at	a	smaller	

size (around	1”)	is	necessary to	fit	on	the	external	shell	of	the	Inspire1/T600	sUAS.		

14	CFR	91.7(a):	Civil	aircraft	airworthiness

This	section	states	that	no	person	may	operate	a	civil	aircraft	unless	it	is	in	an	

airworthy	condition.		

Assuming	no	airworthiness	certificate	will	be	required	due	to	relief	requested	from	

14	CFR	21	(above),	no	regulatory	standard	exists	for	determining	airworthiness.		

The	equivalent	level	of	safety	will	be	achieved	through	the	implementation	of	the	

flight	manual	and	maintenance	manual	procedures,	pilot	training/experience,	and	

analytical	risk	management	for	each	flight.		

14	CFR	91.9(b)(2):		Civil	Aircraft	Flight	Manual	in	the	Aircraft

This	section	states	that	no	person	shall	operate	a	US	registered	civil	aircraft	for	

which	a	rotorcraft	flight	manual	is	not	required	by	§21.5	unless	there	is	available	in	
the	aircraft	a	current	approved	rotorcraft	manual	material,	markings,	and	placards,	

or	any	combination	thereof.		

The	Inspire	1/T600	sUAS,	given	its	size	and	configuration	has	no	ability	or	place	to	

carry	such	a	flight	manual	on	the	aircraft,	not	only	because	there	is	no	pilot	on	

board,	but	because	there	is	no	room	or	physical	capacity	capability	to	carry	such	an	

item	on	the	aircraft.		The	equivalent	level	of	safety	will	be	achieved	by	the	operator	

keeping	the	flight	manual	at	the	ground	control	station,	immediately	accessible	by	

the	operator	during	operations.			Previous	precedence	is	resident	in	Exemptions	

8607,	8737,	f8738,	9299,	9299A,	9565,	9565B,	10167,	10167A,	10602,	f32827,	and	

10700.

14	CFR	91.103:	Preflight	Action

This	section	requires	each	pilot	in	command	to	take	certain	actions	before	flight	to	

insure	the	safety	of	the	flight.		As	FAA	approved	rotorcraft	flight	manuals	will	not	be	

provided	for	the	aircraft	an	exemption	is	requested	for	relief.		An	equivalent	level	of	

safety	will	be	obtained	through	the	operator’s	use	of	the	DJI	Inspire	1	Owners	

manual	along	with	the	petitioner’s/operator’s	safety	plan	outlined	above	(supra).	

Extensive	flight	planning	under	these	practices	will	provide	the	equivalent	level	of	

safety.			

14	CFR	91.109:	Flight	Instruction

This	section	states	that	no	person	shall	operate	a	civil	aircraft	(except	a	manned	free	

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

functioning	dual	controls.
The	Inspire	1/T600	like	almost	all	sUAS	aircraft		by	their	design	do	not	have	fully	

functional	dial	controls.		Flight	control	is	accomplished	through	the	use	of	a	control	

box	that	communicates	with	the	aircraft	via	a	2.4	GHz	radio	communications	link.		

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.		

See	exemption	notes	5778K	and	9862A.		The	equivalent	level	of	safety	provided	by	

the	fact	that	neither	pilot	nor	passengers	will	be	carried	in	the	aircraft	and	training	

would	be	conducted	at	an	FAA	approved	training	site,	operating	under	a	COA.			If	

training	would	be	conducted	it	should	be	noted	that	the	petitioner	holds	a	Certified	

Flight	Instructors	Certificate	(3003234	CFI	exp.	07/2017)	for	single	and	multi	

engine	airplane,	and	instrument	airplane.		

14	CFR	91.119:	Minimum	Safe	Altitudes

This	section	establishes	safe	altitudes	for	operation	of	civil	aircraft.		Section	

91.119(d)	allows	rotorcraft	to	be	operated	at	less	than	the	minimums	prescribed,	

provided	the	person	operating	the	helicopter	to	be	operated	at	less	than	the	

minimums	prescribed,	provided	the	person	operating	the	helicopter	complies	with	

any	route	or	altitudes	prescribed	for	rotorcraft	by	the	FAA.		As	this	exemption	is	for	

a	sUAS,	that	is	a	rotorcraft	and	the	exemption	requests	authority	to	operate	at	

altitudes	from	the	surface	to	400’	AGL,	an	exemption	may	be	needed	to	allow	such	

operations.		As	set	forth	herein,	except	for	the	limited	conditions	stated	in	the	DJI	

Inspire	1/T600	manual,	the	sUAS will	never	operate	at	an	altitude	higher	than	400’	

AGL.		It	will	however	be	operated	in	a	restricted	area	with	a	bounded	security	

perimeter	where	buildings	and	individuals	will	not	be	exposed	to	operations	

without	their	pre-obtained	consent.		This	level	of	safety	will	be	achieved	utilizing	

telemetry	from	the	Inspire	1/T600	sent	back	to	the	operator’s	console.		Telemetry	

includes	the	following	flight	data:	altitude	(AGL),	vertical	and	horizontal	speed,	

direction	and	distance	from	operator.		
The	equivalent level	of	safety	will	be	achieved	given	the	size,	weight,	speed,	of	the	

sUAS	as	well	as	the	location	where	it	will	be	operated	over.		No	flight	will	be	taken	

without	the	permission	of	the	property	owner	or	local	authorities.		Because	of	this	

advance	notice to	the	property	owner,	and	participants,	all	affected	individuals	will	

be	aware	of	the	flight	operations.		Compared	to	flight	operations	with	rotorcraft	or	

fixed	wing	aircraft	weighing	more	far	more	than	the	maximum	55	pounds	proposed	

in	this	exemption	herein	and	the	lack	of	flammable	fuel,	the	risks	involved	we	

believe	are	far	less	than	those	presently	presented	with	conventional	aircraft	used	

for	our	stated	purposes.		In	addition,	a	level	of	safety	to	aircraft	operating	in	the	NAS	

will	be	achieved	through	our	flights	being	at	the	lowest	altitude	possible	below	400’	

AGL,	and	offering	full	right	of	way	to	approaching	aircraft.		

14	CFR	91.121:	Altimeter	Settings

This	section	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	obtained	by	the	operator,	operating	

the	aUAS	pursuant	to	the	manual	and	safety	checklist,	confirming	the	altitude	of	the	

takeoff	site	shown	on	the	GPS	altitude	indicator	before	each	flight.

14	CFR	91.151(a):	Fuel	Requirements	for	Flight	in	VFR	Conditions

This	section	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.		
The	battery	power	system	in	the	DJI	Inspire	1/T600 sUAS	provides	the	aircraft	with	

approximately	25	minutes	of	total	flight	time.	When	the	Inspire	1/T600	battery	is	at	

25%	approx.	10	minutes	of	flight	time	is	left.		As	stated	in	our	safety	plan	above,	the	

sUAS	will	not	be	operated	with	less	than	35%	or	approx.	12 minutes	of	flight	time	

remaining.		The	operator	needs	relief	from	the	30	minute	requirement	stated	in	this	

section	as	that	time	is	longer	than	the	useful	flight	time	of	the	aircraft	altogether.		

14	CFR	91.203(a)	and	(b):	Carrying	Civil	Aircraft Certification	and	Registration

This	section	requires	that	a	person	carry	an	appropriate	airworthiness	certificate	

that	is	displayed	at	the	cabin	or	cockpit	entrance	so	that	it	is	legible	to	passengers	or	

crew.		The	sUAS has	no	onboard	pilot	or	passenger,	and	no	area	to	stow	these	

required	papers.		

An	equivalent level	of	safety	will	be	achieved	by	keeping	these	documents	at	the	

ground	control	point	where	the	pilot	flying	the	sUAS	will	have	immediate	access	to	

them,	to	the	extent	they	are	applicable	to	the	sUAS.		The	FAA	has	issued	numerous	

exemptions	to	this	regulation.		A	representative sample	of	other	exceptions includes	

Exemption	numbers:	9565,	9665,	9789,	9789A,	9797,	9797A,	9816A,	and	10700.

14	CFR	91.405(a),	91.407(a)(1),	91.409(a)(2),	91.417(a)(b):	Maintenance	

Inspections

These	sections	require	that	an	aircraft	operator	or	owner	“shall	have	that	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	other	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	to	the	petitioner.		Maintenance	will	be	accomplished	by	the	operator	pursuant	

to	the	DJI	flight	manual	and	operating	handbook.

An	equivalent	level	of	safety	will	be	achieved	because	these	physically	small	and	

lightweight	small	sUAS’s	are	very	limited	in	size	and	will	carry	a	very	small	payload	

operating	only	in	restricted	operational	areas	for	limited	periods	of	time.		If	

mechanical	issues	arise,	the	sUAS	will	land	immediately	and	will	be	no	higher	than	

400’	AGL.		As provided	in	the	flight	manual,	the	operator	will	ensure	that	the	sUAS	is	

in	working	order	prior	to	starting	a	flight,	performing	any	required	maintenance	

beforehand.		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.		

Closing

Gary	Buzel	is	committed	to	safe	flight	practices,	while	integrating safe	sUAS	

operations	to	the	National	Airspace	System	(NAS).		We	are	confident	in	executing	

commercial	sUAS	operations	that	are	safe,	and	provide	a	service	to	the	public.		

Gary	Buzel	is	prepared	to	respond	to	any	concerns	and	I	look	forward	to	working	

with	the	FAA	on	this	important	exemption.		Please	contact	us	with	any	follow-up	

questions	or	concerns.

Respectfully	Submitted,

__________________________________________

Gary	Buzel

ATP	Pilot	Cert	#	3003234