December 14th, 2015

U.S. Department of Transportation

Docket Management System

1200 New Jersey Ave., SE

Washington, DC 20590

Re: Exemption Request Under Section 333 of the FAA Reform Act and

Part 11 of the Federal Aviation Regulations

Dear Sir or Madam:

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the “Reform Act”) and 14 

C.F.R. Part 11, Motionworks Multimedia, operating the DJI Inspire 1 Unmanned Aircraft System 

(“UAS” or “Inspire”), seeks an exemption from the Federal Aviation Regulations (“FARs”) listed below 

and discussed in Appendix A. 

The requested exemption would permit commercial operation of ESP’s Inspire, which weighs under 7 

lbs. and performs aerial photography and videography using onboard cameras. Applications for these 

UAS devices and associated data processing functions include residential and commercial real 

estate, event coverage, surveying, inspection, and artistic endeavors. Use of the Inspire for aerial 

photography reduces the need to operate conventional aircraft for the same purpose and provides 

very high quality imagery at a fraction of the cost of surveys using conventional aircraft. These 

savings result in enhanced efficiency and productivity for the affected activities, as well as 

environmental benefits.1

Operations under the exemption will be subject to strict operating requirements and conditions to 

ensure at least an equivalent level of safety to currently authorized operations using manned 

aircraft and under conditions as may be modified by the FAA as required by Section 333.

As described more fully below, the requested exemption would authorize commercial operations of 

aerial surveys using the Inspire, which at under 7 lbs. is small in size. The Inspire will be operated 

under controlled conditions at low altitude in airspace that is limited in scope, as described more fully 

herein; it will have automated control features, as described below. 

Motionworks Multimedia respectfully submits that because this small, unmanned aerial vehicle—the

Inspire—will be used in lieu of comparatively hazardous operations now conducted with fixed wing 

and rotary conventional aircraft, the FAA can have confidence that the operations will achieve at 

least an equivalent level or greater level of safety. Approval of this exemption would thereby 

enhance safety and fulfill the Secretary of Transportation’s (the FAA Administrator’s) responsibilities 

under Section 333(c) of the Reform Act to “establish requirements for the safe operation of such 

aircraft systems in the national airspace system.”

1 See, e.g. Jack Nicas, Drones Find Fans Among Farmers, Filmmakers, WALL STREET JOURNAL (March 10, 2014, 7:45 PM) (describing 

how an overseas surveyor used to spend 25,000 Euro ($34,345) to survey 15 square kilometers with a team of 12 surveyors, and it would 

take 2 to 3 weeks to collect all the data. With a Trimble UX5, he accomplished the same task for 5,000 Euro and got all the data he needed in 

3 to 4 days. Because the surveys cost him less to perform, he passes those savings on to his customers.), available at: 

http://online.wsj.com/news/articles/SB10001424052702304732804579425342990070808. 
The name and address of the applicant are: 

Motionworks Multimedia

Attn: Brent Justice

721A Sandy Lane, Surfside Beach, SC 29575

Ph: 843-353-3309

Email: brent@motionworksmultimedia.com

The regulations from which the exemption is requested are as follows:

14 C.F.R. Part 21 

14 C.F.R. 45.23(b) 

14 C.F.R. 61.113(a) & (b) 

14 C.F.R. 61.133(a) 

14 C.F.R. 91.7(b) 

14 C.F.R. 91.9(b)(2) 

14 C.F.R. 91.109(a) 

14 C.F.R. 91.119 

14 C.F.R. 91.151(a) 

14 C.F.R. 91.203(a) & (b) 

14 C.F.R. 91.405(a) 

14 C.F.R. 91.407(a)(1) 

14 C.F.R. 91.409(a)(2) 

14 C.F.R. 91.417(a) 

Appendix A discusses each rule listed above and explains why exemptions pursuant to the proposal 

set forth in this letter are appropriate, provide an equivalent level of safety, and are in the public 

interest.

THE APPLICABLE LEGAL STANDARD UNDER SECTION 333

Motionworks Multimedia submits that grant of this exemption application for use of the Inspire in 

video advertising and precision aerial surveys will advance the Congressional mandate in Section 

333 of the Reform Act to accelerate the introduction of UASs into the national airspace system 

(“NAS”) if it can be accomplished safely. This law directs the Secretary of Transportation to consider 

whether certain UASs may operate safely in the NAS before completion of the 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 or the public or pose a 

threat to national security in light of the following:

• The UAS’s size, weight, speed, and operational capability; 

• Operation of the UAS in close proximity to airports and populated areas; and 

• Operation of the UAS within visual line of sight of the operator. 

Reform Act § 333(a)(1). If the 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.” Id. §333(c).2

2 Applicant submits that this provision places a duty on the Administrator to not only process applications for exemptions 

under Section 333, but for the Administrator, if he deems the conditions proposed herein require modification in order to allow 

approval, to supply conditions for the safe operation of the UAS. ESP welcomes the opportunity to consult with FAA staff in 

order to address any issues or concerns that this proposal may raise that they believe may require modification. 
The Federal Aviation Act expressly grants the FAA the authority to issue exemptions. This statutory 

authority, by its terms, includes exempting civil aircraft, as the term is defined under §40101 of the 

Act, from the requirement that all civil aircraft must have a current airworthiness certificate and those 

regulations requiring commercial pilots to operate aircraft in commercial service:

The Administrator may grant an exemption from a requirement of a regulation prescribed 

under subsection (a) or (b) of this section or any of sections 44702-44716 of this title if the 

Administrator finds the exemption is in the public interest.

49 U.S.C. §44701(f). See also 49 USC §44711(a); 49 USC §44704; 14 CFR §91.203(a)(1).

The grant of the requested exemption is in the public interest based on the clear direction in 

Section 333 of the Reform Act; the additional authority in the Federal Aviation Act, as amended; 

the strong equivalent level of safety surrounding the proposed operations; and the significant 

public benefit, including enhanced safety and cost savings associated with transitioning to UASs 

for aerial survey photography. Accordingly, the applicant respectfully requests that the FAA grant 

the requested exemption without delay.

Airworthiness of the Inspire

A critical element of the exemption application involves evidence of the airworthiness of the 

Inspire. Motionworks Multimedia believes that it is in compliance with the requirements of 

Order 8130.34C, Airworthiness Certification of Unmanned Aircraft Systems and Optionally 

Piloted Aircraft, in its use of systems developed by DJI.3 The Inspire has a high degree of 

redundancy and numerous safety features, including:

Return-to-home failsafe in the event of a loss of communications 

• Configurable limitations for area of operation and altitude 

• Configurable limitations for vertical and horizontal speed 

Additional safety features added by ESP in construction of the Inspire UAS include:

• High visibility lighting system 

• The criteria set forth in the Order specify the substantive showings of the device’s safety and 

fitness for operation ensure that the FAA has sufficient basis to evaluate the aircraft’s safety.

3 Motionworks Multimedia is submitting the following documents in support of this exemption application for the Inspire: 1) 

Inspire Preflight Checklist. 2) Inspire Operations and Maintenance Manual. and 3) Inspire safety Guidelines.
Mandatory Operating Conditions

Grant of the exemption to ESP will be subject to the following mandatory conditions, which are 

based upon operating conditions set forth for operation of UAS by public entities pursuant to 

Certificates of Authorization, with additional restrictions:

• All operations to occur in Class G airspace. 

• Operations to avoid congested or populated areas, which are depicted in yellow on VFR 

charts. 

• Operations to be conducted over private or controlled-access property. 

• Permission from land owner/controller required before commencing any flight. 

• Operations to occur during Visual Flight Rules Meteorological Conditions (VMC). 

• Aircraft to remain within Visual Line of Sight (VLOS). 

o VLOS guaranteed with a cylinder of operation around operator of 1⁄2 nautical miles 

(NM). 

o Cylinder walls may be expanded by observer with ability to control aircraft. 

• Above Ground Level (AGL) altitude to be restricted to 400 feet. 

• All operations conducted in vicinity of airport to remain more than 2.5 NM from centerline 

azimuth of runway centerline measured from runway thresholds. 

• All required permissions and permits will be obtained from territorial, state, county or city 

jurisdictions including local law enforcement, fire, or other appropriate governmental 

agencies. 

Operator Requirements

Motionworks Multimedia respectfully proposes that operator requirements should take into 

account the characteristics of the particular UAS. Certain UASs, such as the DJI Inspire, are 

characterized by a high degree of pre- programmed control and various built-in technical 

capabilities that limit the potential for operation outside of the operating conditions set forth 

above.

The Inspire has a semi-autonomous navigation and control system comprised of a Ground Control 

Station (GCS) and auto-pilot system. All flights are pre-programmed with GPS guidance and do not 

require human intervention. Flight mission area and routing cannot be changed after launch. Flights 

are not directed by positive manual control, nor are evasive maneuvers. In the case of unplanned

events, the operator inputs pre-programmed evasive maneuvers from the control unit and the control 

unit executes that maneuver. Pre-programmed operator interventions include diversion to the right;

initiation of holding at present position; suspension of mission; fly back to launch point; fly to point and 

hold; abort mission and land; and emergency power cut off and land (Flight Termination System).

Additional automated safety functions and safety enhancing features of the Inspire include the 

following:

• Auto-pilot detection of lost GPS or of insufficient satellites initiates an immediate vertical 

landing, unless overridden by pilot in command. 

• Low power on the aircraft triggers escalating alarms at GCS at 35% and 10% levels. 

• If the auto-pilot detects a lost-link to the GCS for longer than 30 seconds, return-to-home 

sequence initiates. 

• The Inspire is inherently unstable, so auto-pilot failure will result in a rapid exit from flight. 

• Aircraft has an on-board failsafe that limits vertical speed to approximately 6 m/s 

(configurable). 

• The aircraft, weighing less than 7 lbs., fully loaded, is constructed of composite material 

intended to absorb impact energy. 

• The motors are driven by pulse width modulated signals, not analog signals. 
Given these safety features, Motionworks Multimedia proposes that operators of the Inspire should 

not be required to hold a commercial or private pilot certification. Instead, operators should be 

required to have successfully demonstrated capability to operate UAS in accordance with 

manufacturer standards. 

Motionworks Multimedia notes that the FAA has found that safety factors permitted operation of 

UASs by operators with these qualifications in the case of operations pursuant to public COAs when 

the mandatory operating conditions specified above were present. See Federal Aviation 

Administration, Notice N-8900.227, Unmanned Aircraft Systems (UAS) Operational Approval, at 20-

21 (July 30, 2013). The FAA has the statutory authority to grant exemptions to the requirements for 

and privileges associated with the grant of airmen’s certificates. 49 USC §44701 (f).

In summary, applicant seeks an exemption from the FARs set forth above and in Appendix A to 

allow commercial operations of a small unmanned vehicle conducting precision video production for 

advertising purposes and aerial surveys. Approval of the exemption allowing commercial operations 

of the Inspire for video production and precision survey work will enhance safety by reducing risk. 

Conventional aerial survey operations, using jet or piston-powered aircraft present risks associated 

with vehicles that weigh in the neighborhood of 5,000 to 7,000 lbs., or more, carry large quantities of 

fuel, passengers, and, in some cases, cargo. Such aircraft must fly to and from the survey location. 

In contrast, a Inspire weighing less than 7 lbs. and powered by batteries eliminates a portion of that 

risk given the reduced mass and lack of combustible fuel carried on board. The Inspire is carried to 

the survey location, not flown there. The Inspire will carry no passengers or crew and, therefore, will 

not expose any individuals to the risks associated with manned aircraft flights.

Additionally, no national security issue is raised by the grant of the requested exemptions. Given the 

size, load carrying capacity, speed at which it operates, and the fact that it carries no explosives or 

other dangerous materials, the Inspire poses no threat to national security.

The operation of the Inspire, weighing less than 7 lbs., for precision surveys in accordance with the 

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

exemptions requested herein, including exempting ESP from the requirements of Part 21.

The Inspire’s satisfaction of the criteria set forth in Section 333 of the Reform Act—size, weight, 

speed, operating capabilities, lack of proximity to airports and populated areas, operation within 

visual line of sight, and national security—and its showing of an equivalent level of safety as it may 

relate to the requirement for a pilot’s license, provide more than adequate justification for the grant of 

the requested exemptions allowing commercial operation of the Inspire in the commercial video 

production and precision aerial survey business.

Very Respectfully,

Brent Justice

Motionworks Multimedia
APPENDIX A

EXEMPTION REQUEST AND EQUIVALENT LEVEL OF SAFETY SHOWINGS UNDER 

APPLICABLE RULES SUBJECT TO EXEMPTION

Motionworks Multimedia requests an exemption from the following regulations as well as any 

additional regulations that may technically apply to the operation of the Inspire:

14 C.F.R. § 45.23(b): Marking of the Aircraft

The regulation provides:

When marks include only the Roman capital letter “N” and the registration number is displayed 

on limited, restricted or light-sport category aircraft or experimental or provisionally certificated 

aircraft, the operator must also display on that aircraft near each entrance to the cabin, 

cockpit, or pilot station, in letters not less than 2 inches nor more than 6 inches high, the 

words “limited,” “restricted,” “light-sport,” “experimental,” or “provisional,” as applicable.

The Inspire has no entrance to the cabin, cockpit, or pilot station on which the word “Experimental” 

can be placed. Given the size of the UAV, two-inch lettering will be impossible. The word 

“Experimental” will be placed on the forward fuselage in compliance with § 45.29(f).

The equivalent level of safety will be achieved by having the Inspire marked as required by § 

45.29(f) where the pilot, observer, and others working with the UAV will see the identification of the 

UAS as “Experimental.” The FAA has issued the following exemptions to this regulation, Exemption 

Nos. 10700, 8738, 10167 and 10167A.

14 C.F.R. Part 21, Subpart H: Airworthiness Certificates 14 CFR § 91.203(a)(1)

Section 91.203(a)(1) requires all civil aircraft to have a certificate of airworthiness. Part 21, Subpart H, 

entitled Airworthiness Certificates, establishes the procedural requirements for the issuance of 

airworthiness certificates as required by FAR § 91.203(a)(1). Given the size of the aircraft (under 

7lbs.) and the limited operating area associated with its utilization, it is unnecessary to go through the 

certificate of airworthiness process under Part 21 Subpart H to achieve or exceed current safety 

levels. Such an exemption meets the requirements of an equivalent level of safety under Part 11 and 

Section 333 of the Reform Act. The Federal Aviation Act 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 size, weight, speed, operational capability, and proximity to airports and 

populated areas of the UAS involved.

In this case, an analysis of these criteria demonstrates that the Inspire operated without an 

airworthiness certificate, under the conditions proposed herein, will be at least as safe, or safer, than a 

conventional aircraft (fixed wing or rotorcraft) with an airworthiness certificate. The Inspire weighs less 

than 7 lbs. fully loaded. It will not carry a pilot or passenger, will not carry flammable fuel, and will 

operate exclusively within an area pre-disclosed and in compliance with conditions set forth herein. 

Operations under this exemption will be tightly controlled and monitored by both the operator, 

pursuant to the conditions set forth above, and by local public safety requirements. The FAA will have 

advance notice of all operations through the filing of NOTAMs. Receipt of the prior permission of the 

land owner, the size of the aircraft, the lack of flammable fuel, and the fact that the aircraft is carried to 
the location and not flown there all establish the equivalent level of safety. The Inspire construction 

with absorbent material provides at least an equivalent level of safety to that of such operations being 

conducted with conventional aircraft that would be orders-of-magnitude larger and would be carrying 

passengers, cargo, and flammable fuel.

14 C.F.R. § 61.113(a) & (b); 61.133(a): Private Pilot Privileges and Limitations; Pilot in 

Command; Commercial Pilot Privileges and Limitations.

Section 61.113(a) & (b) limit private pilots to non-commercial operations. Unlike a conventional 

aircraft that carries a pilot, passengers, and cargo, the Inspire in this case is remotely controlled with 

no passengers or property of others on board. Section 61.133(a) requires an individual with a 

commercial pilot’s license to be pilot in command of an aircraft for compensation or hire. Motionworks 

Multimedia respectfully proposes that operator requirements should take into account the 

characteristics of the particular UAS. Motionworks Multimedia’s Inspire has a high degree of preprogrammed control and various built-in technical capabilities that strictly limit the potential for 

operation outside of the operating conditions set forth in the exemption application.

The Inspire has a semi-autonomous navigation and control system comprised of a Ground Control 

Station (GCS) and auto-pilot system. All flights are pre-programmed with precision GPS guidance and 

do not require human intervention. Flight mission area and routing cannot be changed after launch. 

Flights are not directed by positive manual control, nor are evasive maneuvers. In the case of 

unplanned events, the operator inputs pre-programmed evasive maneuvers from the control unit, and 

the control unit executes that maneuver. Pre-programmed operator interventions include diversion to 

the right; initiation of holding at present position; suspension of mission; fly back to launch point; fly to 

point and hold; abort mission and land; and emergency power cut off and land (Flight Termination 

System).

Additional automated safety functions and safety enhancing features of the Inspire include 

the following:

• Auto-pilot detection of lost GPS or of insufficient satellites initiates an immediate spiral landing. 

• Low power on the aircraft triggers escalating alarms at GCS at 35% and 10% levels. 

• If the auto-pilot detects a lost-link to the GCS for longer than 30 seconds, landing procedure begins. 

• The Inspire is inherently unstable, so auto-pilot fail will result in very rapid exit from flight. 

• Aircraft has an on-board failsafe that limits speed in the event of dive to approximately 14 m/s. 

• The aircraft, weighing less than 7 lbs., fully loaded, is constructed of composite material, which is 

intended to absorb impact energy. 

• The motors are driven by pulse width modulated signals, not analog signals.

Motionworks Multimedia notes that the FAA has found that safety factors permitted operation of 

UASs by operators with these qualifications in the case of operations pursuant to public COAs 

where the mandatory operating conditions specified above are present. See Federal Aviation 

Administration, Notice N-8900.227, Unmanned Aircraft Systems (UAS) Operational Approval, at 20-

21 (July 30, 2013). The FAA has the statutory authority, granted at 49 U.S.C.§44701(f) to waive the 

pilot requirements for commercial operations.

Given these conditions and restrictions, an equivalent level of safety will be provided by allowing 

operation of the Inspire without a private pilot’s certificate or a commercial pilot’s certificate, under the 

conditions set forth herein.
The risks associated with the operation of the Inspire (given its size, speed, operational capabilities, 

and lack of combustible fuel) are so diminished from the level of risk associated with private pilot 

operations or commercial operations contemplated by Part 61 with conventional aircraft (fixed wing or 

rotorcraft), that allowing operations of the UAS as set forth above meets or exceeds the present level 

of safety provided under 14 C.F.R. § 61.113(a) & (b) and does not rise to the level of requiring a 

commercial pilot to operate the aircraft under § 61.133(a).

14 C.F.R. § 91.7(a): Civil aircraft airworthiness.

This regulation requires that no person may operate a civil aircraft unless it is in airworthy condition. 

Should the exemption be granted allowing commercial operation of the Inspire without an 

airworthiness certificate, no standard will exist for airworthiness of the Inspire. Given the size of the 

aircraft and the requirements that have presumably already been met in the SAC approval process 

for the Inspire (for instance, the Inspire’s Maintenance & Inspection Manual and Safety Checklist), 

an equivalent level of safety will be achieved by insuring compliance with the DJI manuals prior to 

each flight.

14 C.F.R. § 91.9(b)(2): Civil Aircraft Flight Manual in the Aircraft.

The regulation provides:

No person may operate a U.S.-registered civil aircraft ...

(2)...For which an Airplane or Rotorcraft Flight Manual is not required by §21.5 of this chapter, 

unless there is available in the aircraft a current approved airplane or Rotorcraft Flight Manual, 

approved manual material, markings, and placards, or any combination thereof.

Given the size and configuration of the Inspire, it 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 capacity 

to carry such an item on the aircraft.

The equivalent level of safety will be achieved by keeping the flight manual at the ground control 

point where the pilot flying the UAS will have immediate access to it. The FAA has issued the 

following exemptions to this regulation: Exemption Nos. 8607, 8737, 8738, 9299, 9299A, 9565, 

9565B, 10167, 10167A, 10602, 32827, and 10700.

14 C.F.R. § 91.109(a) & 91.319(a)(1): Flight Instruction

These regulations provide 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.

The Inspire is a remotely piloted aircraft and by design, does not have fully functional dual controls. 

Flight control is accomplished through the use of a control box that communicates with the aircraft via 

radio communications. The flight plan is pre-programmed into the auto pilot before flight and only in 

unusual circumstances will the pilot input control functions to alter the pre-programmed flight. If 

instruction is accomplished through a training program an equivalent level of safety will be assured. 

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 Nos. 5778K & 

9862A. The equivalent level of safety will be achieved by the manufacturer providing the training as 

outlined, for example, in DJI Manuals and through the use of experienced and qualified pilots familiar 

with the Inspire.
14 CFR § 91.119: Minimum Safe Altitudes

Section 91.119 establishes safe altitudes for operation of civil aircraft. Specifically, 91.119(c) limits 

aircraft flying over areas other than congested areas to an altitude of 500 feet above the surface, 

except over open water or sparsely populated areas. In those cases, the aircraft may not be operated 

closer than 500 feet to any person, vessel, vehicle, or structure.

As set forth herein, the Inspire will never operate at higher than 400 feet AGL. It will, however, be 

operated to avoid congested or populated areas that are depicted in yellow on VFR sectional 

charts. Because aerial survey work must be accomplished at relatively low altitudes and at 

altitudes less than 500 feet AGL, an exemption from Section 91.119(c) is needed.

The equivalent level of safety will be achieved given the size, weight, speed, and material with which 

the Inspire is built. Also, no flight will be taken without the permission of the land owner or those who 

control the land. Because of the advance notice to the landowner, all affected individuals will be 

aware of the survey flights. Compared to aerial survey operations conducted with aircraft or rotorcraft 

weighing far more than 7 lbs. and carrying flammable fuel, any risk associated with these operations 

will be far less than those currently allowed with conventional aircraft operating at or below 500 feet 

AGL. Indeed, the low-altitude operations of the UAS will maintain separation between these smallUAS operations and the operations of conventional aircraft that must comply with Section 91.119.

14 C.F.R. § 91.151(a): Fuel Requirements for Flight in VFR Conditions

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 Inspire batteries provide approximately 50 minutes of powered flight. Without an exemption from 

§ 14 CFR 91.151, the UAS’s flights would be limited to approximately 20 minutes in length. Given the 

limitations on its proposed operations and the location of those proposed operations, a longer time 

frame for flight in daylight VFR conditions is reasonable.

Motionworks Multimedia believes that an exemption from 14 CFR § 91.151(a) is safe and within the 

scope of a prior exemption. See Exemption 10673 (allowing Lockheed Martin Corporation to 

operate without compliance with 91.151(a)). Operating the small UAS, without 30 minutes of 

reserve fuel does not engender the type of risks that Section 91.151(a) was meant to prevent given 

the size and speed at which the UAS operates. The fact that it carries no pilot, passenger, or cargo 

also enhances its safety. Additionally, limiting Inspire flights to 20 minutes would greatly reduce 

their utility. In the unlikely event that the Inspire should run out of fuel, it would simply land. Given its 

weight and construction material, the risks are less than contemplated by the current regulation.

Motionworks Multimedia believes that an equivalent level of safety can be achieved by maintaining 

10 percent of reserve fuel, which, allowing 40 minutes of flight time, would be more than adequate 

to return the UAS to its planned landing zone from anywhere in its operating area.
14 C.F.R. § 91.203 (a) & (b): Carrying Civil Aircraft Certification and Registration

This regulation provides as follows:

(a)...no person may operate a civil aircraft unless it has...an appropriate and current 

airworthiness certificate.

(b) No person may operate a civil aircraft unless the airworthiness certificate required by 

paragraph (a) of this section or a special flight authorization issued under §91.715 is 

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

The Inspire fully loaded weighs no more than 7 lbs. As such, there is no ability or place to carry 

certification and registration documents or to display them on the UAS. In addition, there is no pilot on 

board the aircraft.

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

point where the pilot flying the UAS will have immediate access to them. The FAA has issued 

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

Exemption Nos. 9565, 9665, 9789, 9789A, 9797, 9797A, 9816A, and 10700.

14 C.F.R. § 91.405(a); 407(a)(1); 409(a)(2); 417(a): Maintenance Inspections

Section 91.405(a) requires 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...” 

Section 91.407 similarly makes reference to requirements in Part 43; Section 91.409(a)(2) requires 

an annual inspection for the issuance of an air worthiness certificate. Section 91.417(a) requires the 

owner or operator to keep records showing certain maintenance work that has been accomplished by 

certificated mechanics, under Part 43, or licensed pilots and records of approval of the aircraft for 

return to service.

Maintenance of the Inspire will be accomplished by the owner/operator pursuant to the manuals, 

provided by Motionworks Multimedia. An equivalent level of safety will be achieved because the UAS 

is small in size, will operate only in restricted predetermined areas, and is not a complex mechanical 

device. As provided in the attached User Manual and the Safety Checklist, the operator of Inspire will 

ensure that the UAS is in working order prior to initiating flight, perform required maintenance, and 

keep a log of any maintenance that is performed. Moreover, the operator is the person most familiar 

with the aircraft and is best suited to maintain the aircraft in an airworthy condition and to ensure an 

equivalent level of safety.
APPENDIX B

SUMMARY OF MOTIONWORK MULTIMEDIA SECTION 333 EXEMPTION REQUEST

Motionworks Multimedia hereby provides pursuant to Part 11 a summary of its exemption 

application to allow commercial operation of the Inspire unmanned aircraft in advertising and survey

work. An exemption is requested from the following regulations:

14 C.F.R. Part 21 

14 C.F.R. 45.23(b) 

14 C.F.R. 61.113(a) & (b) 

14 C.F.R. 61.133(a) 

14 C.F.R. 91.7(b) 

14 C.F.R. 91.9(b)(2) 

14 C.F.R. 91.109(a) 

14 C.F.R. 91.119 

14 C.F.R. 91.151(a) 

14 C.F.R. 91.203(a) & (b) 

14 C.F.R. 91.405(a) 

14 C.F.R. 91.407(a)(1) 

14 C.F.R. 91.409(a)(2) 

14 C.F.R. 91.417(a)