UNITED STATES OF AMERICA 

DEPARTMENT OF TRANSPORTATION 

FEDERAL AVIATION ADMINISTRATION 

WASHINGTON, DC 

Regulatory Docket No. 

IN THE MATTER OF THE PETITION FOR EXEMPTION OF:

Christian Nowosiadly

FOR AN EXEMPTION SEEKING RELIEF FROM THE REQUIREMENTS OF 

TITLE 14 OF THE CODE OF FEDERAL REGULATIONS

SECTIONS 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 

91.409(a)(1) & (a)(2), AND 91.417(a) & (b) CONCERNING COMMERCIAL 

OPERATION OF DJI Inspire 1 (Model T600)UNMANNED AIRCRAFT 

SYSTEM

PURSUANT TO SECTION 333 OF

THE FAA MODERNIZATION AND REFORM ACT OF 2012 

(PUBLIC LAW 112-95)

Submitted on Sep 22th, 2015 

Christian Nowosiadly 

45 Leyden Street 

Boston, MA 02128 

(617) 501-3437
GLOSSARY OF ABBREVIATIONS

AGL Above Ground Level 

AOI Area of Interest 

ATC Air Traffic Control 

ATO Air Traffic Organization 

AV Aerial Vehicle 

CFR Code of Federal Regulations 

COA Certificate of Authorization 

FAA Federal Aviation Administration 

FAR Federal Aviation Regulation 

GCS Ground Control Station 

GPS Global Positioning System 

LOL Loss of Link 

NAS National Airspace System 

NOTAM Notice to Airman 

PIC Pilot In Command 

Section 333 FAA Modernization and Reform Act of 2012 (FMRA) Section 333 

SO Safety Observer 

SOP Standard Operating Procedures 

UA Unmanned Aircraft 

UAS Unmanned Aircraft System 

VFR Visual Flight Rules 

VLOS Visual Line of Site 

VMC Visual Meteorological Conditions 

VTOL Vertical Takeoff and Landing 

SUMMARY

Christian Nowosiadly seeks exemption from the requirements of 14 C.F.R §§ 61.113(a) & 

(b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a) (2), and 91.417(a) & (b), to 

operate an Unmanned Aircraft System pursuant to Section 333 of the FAA Modernization and 

Reform Act of 2012 (FMRA). This exemption will permit Christian Nowosiadly to operate an 

Unmanned Aircraft System (UAS) for the commercial purpose of conducting aerial video and 

photography of construction sites, real estate, and landscape over certain areas of the United States. 

INTRODUCTION AND INTERESTS OF THE PETITIONER

Christian Nowosiadly has active ATP Multi-Engine land, Commercial Helicopter, and CFI 

Airplane ratings, as well as achieving the Master Wings phase through the FAAST program. 

Christian Nowosiadly owns a successful helicopter tour and Aerial Photography business operating 

in the New England area for over 4 years, providing his clients with expertise and knowledge of 

working inside the National Airspace System to satisfy their project. Christian Nowosiadly has over 4 

years of professional experience in Aerial Photography along with being an AMA model Aircraft 

hobbiest for 6 years flying both rotor and fixed wing aircraft. The objective of Christian 

Nowosiadly’s aerial video and photography operations is to provide high quality imaging for a variety 

of commercial, public, and residential uses, specifically targeting: 

• Construction sites before and after 

• Appraisals 

• Real-estate marketing 

• Motion Picture Filming 

• Aerial acquisitions used for inspections of public and private structures. 

• Search and Rescue operations

• Charity Events
BACKGROUND

Unmanned Aircraft Systems: DJI Inspire 1 (Model T600) UASs 

Christian Nowosiadly seeks an exemption to operate DJI systems for compensation or hire 

within the NAS. The DJI Inspire 1 (Model T600) UASs are vertical takeoff and landing (VTOL) 

Unmanned Aircraft (UA) with a Ground Control Station (GCS) utilizing electronic tablet or smart 

phone systems. The DJI Inspire 1 (Model T600) has a maximum gross weight of approximately 

7.75 pounds, while having a length of 17 inches width of 18 inches, height of 12 inches, and a 

maximum speed of approximately 43 knots. The DJI Inspire 1 (Model T600) UAs are equipped 

with four main rotors; driven by Lithium Polymer battery powered electric motors. 

The DJI Inspire 1 (Model T600) UAs that will be operated by Christian Nowosiadly will 

be registered in accordance with 49 U.S.C. 44103, Registration of Aircraft, as well as 14 C.F.R Part 

47, Aircraft Registration, and marked in accordance with 14 C.F.R. Part 45, Identification and 

Registration Marking. 

BASIS FOR PETITION

Petitioner, Christian Nowosiadly, pursuant to the provisions of the Federal Aviation 

Regulations (14 

C.F.R. § 11.61) and the FAA Modernization and Reform Act of 2012 (FMRA), Section 333, Special 

Rules for Certain Unmanned Aircraft Systems, hereby petitions the Administrator to commercially operate 

the DJI Inspire 1 (Model T600) UASs in the National Airspace System (NAS), and for an 

exemption from the requirements of 14 C.F.R §§ 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 

91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b). 

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

unmanned aircraft and its operation, Christian Nowosiadly operation of DJI Inspire 1 (Model 
T600) UASs meets the conditions of FMRA Section 333 and therefore, will not require an 

airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H.

Accordingly, Christian Nowosiadly requests relief from Sections 91.405(a), 91.407(a)(1), 

91.409(a)(1) & (a)(2), and 91.417(a) & (b), as these sections set forth requirements for maintenance 

that only apply to aircraft with an airworthiness certificate. Christian Nowosiadly submits that the 

requested relief is proper since an equivalent level of safety will be ensured. Christian Nowosiadly 

will use experienced personnel or technicians to perform maintenance, alterations, or preventive 

maintenance on the UASs using the methods, techniques, and practices prescribed in the operating 

documents (i.e., Monthly Maintenance Log, and DJI Inspire 1 (Model T600) Instruction Manual). 

Furthermore, Christian Nowosiadly will document and maintain all maintenance records for the 

DJI Inspire 1 (Model T600) UASs. 

Relief from certain requirements of Section 61.113(a) and (b), entitled Private pilot privileges 

and limitations: Pilot in command, is requested by Christian Nowosiadly to the extent necessary to allow 

a Pilot in Command (PIC) not holding a certificate, or an airman medical certificate, and who has 

demonstrated, by meeting minimum flight-hour and currency requirements, that the PIC is able to 

safely operate the DJI Inspire 1 (Model T600) UASs in a manner consistent with this exemption, 

including evasive and emergency maneuvers and maintaining appropriate distances from people, 

vessels, vehicles and structures. 

Christian Nowosiadly seeks relief from Section 91.7(a), entitled Civil aircraft airworthiness, 

because the DJI Inspire 1 (Model T600) UASs do not require an airworthiness certificate in 

accordance with 14 C.F.R. Part 21, Subpart H. As such, Christian Nowosiadly submits that he will 

ensure that the DJI Inspire 1 (Model T600) UASs are in an airworthy condition, prior to every 

flight, by determining that the UASs are in compliance with the operating documents (i.e., 

Monthly Maintenance Log, and DJI Inspire 1 (Model T600) Instruction Manual), and that the 

aircraft are in a condition for safe flight. 
Christian Nowosiadly also seeks an exemption from the requirements of Section 91.121, 

entitled Altimeter Settings, as the DJI Inspire 1 (Model T600) UAs will not have a typical barometric 

altimeter onboard. However, altitude information of the DJI Inspire 1 (Model T600) UAs will be 

provided to the PIC via Global Positioning System (GPS) equipment and radio communications 

telemetry data link, which own links from the UA to the GCS for active monitoring of the flight 

path. This altitude information, combined with Christian Nowosiadly’s operation of the DJI Inspire 

1 (Model T600) UASs within visual line of sight, at or below 400 feet AGL, will ensure a level of 

safety equivalent to Section 91.121. 

Additionally, Christian Nowosiadly seeks an exemption from the requirements of Section 

91.151(b), entitled Fuel requirements for flight in VFR conditions. Christian Nowosiadly submits that 

safety will not be affected by operation of the DJI Inspire 1 (Model T600) UAs during daylight 

hours in visual meteorological conditions (VMC) under visual flight rules (VFR), with enough 

battery power to fly for a total duration of approximately 13.5 minutes to the first point of intended 

landing and, assuming normal cruising speed, to fly after that for at least 4.5 minutes. 

In accordance with 14 C.F.R. § 11.81, Christian Nowosiadly provides the following 

information in support of its petition for exemption: 

A. Name And Address Of The Petitioner.

The name and address of the Petitioner and point of contact is: 

Christian Nowosiadly 

45 Leyden St 

Boston, MA 02128 

Email: christian@nowcitytours.com 

B. The Specific Sections Of 14 C.F.R. From Which Christian Nowosiadly Seeks Exemption.

1. Christian Nowosiadly Seeks Exemption From The Requirements Of Section 61.113(a) And 

(b).

Section 61.113, entitled Private pilot privileges and limitations: Pilot in command, subsections (a) and 
(b) prescribe the following, in relevant part: 

(a) No person who holds a private pilot certificate may act as a pilot in command (PIC) 

of an aircraft that is carrying passengers or property for compensation or hire; nor 

may that person, for compensation or hire, act as PIC of an aircraft. 

(b) A private pilot may, for compensation or hire, act as PIC of an aircraft in 

connection with any business or employment if— 

(1) The flight is only incidental to that business or employment; and 

(2) The aircraft does not carry passengers or property for compensation or hire. 

2. Christian Nowosiadly Seeks Exemption From The Requirements Of Section 91.7(a).

Section 91.7, entitled Civil aircraft airworthiness, subsection (a), states the following: 

(a) No person may operate a civil aircraft unless it is in an airworthy condition. 

3. Christian Nowosiadly Seeks Exemption From The Requirements Of Section 91.121.

Section 91.121, entitled Altimeter settings, subsection (a), states the following, in part: 

(a) Each person operating an aircraft shall maintain the cruising altitude or flight level 

of that aircraft, as the case may be, by reference to an altimeter that is set, when 

operating— 

(1) Below 18,000 feet MSL, to-- 

(i) The current reported altimeter setting of a station along the route and 

within 100 nautical miles of the aircraft; 

(ii) If there is no station within the area prescribed in paragraph (a)(1)(i) of 

this section, the current reported altimeter setting of an appropriate 

available station; or 

(iii) In the case of an aircraft not equipped with a radio, the elevation of 

the departure airport or an appropriate altimeter setting available 

before departure. 

4. Christian Nowosiadly Seeks Exemption From The Requirements Of Section 91.151(b).

Section 91.151, entitled Fuel requirements for flight in VFR conditions, subsection (b), states the following: 

(b) No person may begin a flight in a rotorcraft 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, to fly after that for at least 20 minutes.

5. Christian Nowosiadly Seeks Exemption From The Requirement Of Section 91.405(a).

Section 91.405, entitled Maintenance required, subsection (a), states the 
following: Each owner or operator of an aircraft— 

(a) 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[.] 

6. Christian Nowosiadly Seeks Exemption From The Requirements Of Section 

91.407(a)(1) Section 91.407, entitled Operation after maintenance, preventive maintenance, 

rebuilding, or alteration, subsection (a)(1), states the following: 

(a) No person may operate any aircraft that has undergone maintenance, preventive 

maintenance, rebuilding, or alteration unless-- 

(1) It has been approved for return to service by a person authorized under § 43.7 of 

this chapter[.] 

7. Christian Nowosiadly Seeks Exemption From The Requirements Of Sections 

91.409(a)(1) And 91.409(a)(2).

Section 91.409, entitled Inspections, subsection (a), states the following: 

(a) Except as provided in paragraph (c) of this section, no person may operate an aircraft 

unless, within the preceding 12 calendar months, it has had – 

(1) An annual inspection in accordance with part 43 of this chapter and has been approved 

for return to service by a person authorized by § 43.7 of this chapter; or 

(2) An inspection for the issuance of an airworthiness certificate in accordance with part 21 

of this chapter. 

8. Christian Nowosiadly Seeks Exemption From The Requirements Of Sections 

91.417(a) And 91.417(b).

Section 91.417, entitled Maintenance records, subsections (a) and (b), state the following: 

(a) Except for work performed in accordance with §§ 91.411 and 91.413, each registered 

owner or operator shall keep the following records for the periods specified in paragraph 

(b) of this section: 

(1) Records of the maintenance, preventive maintenance, and alteration and records of the 

100-hour, annual, progressive, and other required or approved inspections, as 

appropriate, for each aircraft (including the airframe) and each engine, propeller, rotor, 

and appliance of an aircraft. The records must include— 
(i) A description (or reference to data acceptable to the Administrator) of the 

work performed; and 

(ii) The date of completion of the work performed; and 

(iii) The signature, and certificate number of the person approving the aircraft 

for return to service. 

(2) Records containing the following information: 

(i) The total time in service of the airframe, each engine, each propeller, and each rotor. 

(ii) The current status of life-limited parts of each airframe, engine, propeller, rotor, 

and appliance. 

(iii) The time since last overhaul of all items installed on the aircraft which are 

required to be overhauled on a specified time basis. 

(iv) The current inspection status of the aircraft, including the time since the last 

inspection required by the inspection program under which the aircraft and 

its appliances are maintained. 

(v) The current status of applicable airworthiness directives (AD) and safety 

directives including, for each, the method of compliance, the AD or safety 

directive number and revision date. If the AD or safety directive involves 

recurring action, the time and date when the next action is required. 

(vi) Copies of the forms prescribed by § 43.9(d) of this chapter for each major 

alteration to the airframe and currently installed engines, rotors, propellers, and 

appliances. 

(b) The owner or operator shall retain the following records for the periods prescribed: 

(1) The records specified in paragraph (a)(1) of this section shall be retained 

until the work is repeated or superseded by other work or for 1 year after the 

work is performed. 

(2) The records specified in paragraph (a)(2) of this section shall be retained 

and transferred with the aircraft at the time the aircraft is sold. 

(3) A list of defects furnished to a registered owner or operator under § 43.11 of this 

chapter shall be retained until the defects are repaired and the aircraft is approved 

for return to service. 

C. The Extent Of Relief Christian Nowosiadly Seeks And The Reason Christian 

Nowosiadly Seeks The Relief.

1. Extent Of Relief Christian Nowosiadly Seeks And The Reason Christian Nowosiadly 

Seeks Relief From Section 61.113(a) And (b).

Relief from Section 61.113(a) and (b) entitled Private pilot privileges and limitations: Pilot in 

command, is requested to the extent necessary to allow a PIC not holding any pilot certificate, or a 

current and valid airman medical certificate, but who has met certain flight-hour and currency 
requirements, to conduct the proposed UAS flight operations for compensation or hire. 

This relief is requested since the limitations set forth in Section 61.113(a) and (b) state that a 

private pilot may, for compensation or hire, act as PIC of an aircraft in connection with any 

business or employment if: 

(1) The flight is only incidental to that business or employment; and 

(2) The aircraft does not carry passengers or property for compensation or hire. 

As set forth more fully below, Christian Nowosiadly submits that an equivalent level of safety will 

be maintained because no PIC will be allowed to operate the DJI Inspire 1 (Model T600) UAS 

unless that PIC has met certain flight-hour and currency requirements, demonstrating that the PIC 

is able to safely operate the DJI Inspire 1 (Model T600) in a manner consistent with the operations 

specifications as described in this exemption, including evasive and emergency maneuvers, as well 

as maintaining appropriate distances from people, vessels, vehicles and structures. 

Further, Christian Nowosiadly submits that all flights of the DJI Inspire 1 (Model T600) UASs, 

conducted by the PIC pursuant to the grant of this Petition: 

(1) will be incidental to Christian Nowosiadly's business; and 

(2) will not carry passengers or property for compensation or hire. 

2. Extent Of Relief Christian Nowosiadly Seeks And The Reason Christian Nowosiadly 

Seeks Relief From Section 91.7(a).

Relief from Section 91.7(a) entitled Civil aircraft airworthiness, is requested to the extent required to 

allow Christian Nowosiadly to determine that the DJI Inspire 1 (Model T600) UASs are in 

airworthy condition prior to every flight by ensuring that the UAS is in compliance with the 

operating documents (i.e., the Christian Nowosiadly Aerial Operations Manual, Monthly 

Maintenance Log, and DJI Inspire 1 (Model T600) Instruction Manual). Christian Nowosiadly 

seeks the requested relief because the DJI Inspire 1 (Model T600) UASs do not require an 
airworthiness certificate in accordance with 14 

C.F.R. Part 21, Subpart H. Therefore, Christian Nowosiadly will ensure that the DJI Inspire 1 

(Model T600) UASs are in airworthy condition based upon its compliance with the operating 

documents (i.e., Monthly Maintenance Log, and DJI Inspire 1 (Model T600) Instruction Manual) 

prior to every flight, and further, determine that the aircraft are in condition for safe flight, as stated 

in the conditions and limitations below. 

Extent Of Relief Christian Nowosiadly, Seeks From Section 91.121.

Relief from Section 91.121, entitled Altimeter settings, may be required to allow flight operations of 

the DJI Inspire 1 (Model T600)UASs, which utilize a barometric pressure sensor, GPS equipment, 

and a radio communications telemetry data link to downlink altitude information from the UA to 

the PIC at the ground control station (GCS). Since the FAA requires that any altitude information 

concerning UAS operations be reported to air traffic control (ATC) in feet above ground level 

(AGL), Christian Nowosiadly seeks the requested relief because the DJI Inspire 1 (Model T600) 

UA’s altimeter may be set on the ground to zero feet AGL, rather than the local barometric 

pressure or field altitude, before each flight. 

Considering the limited altitude of the proposed operations, relief from 14 CFR 91.121 is sought to 

the extent necessary to comply with the applicable conditions and limitations stated below. As more 

fully set forth herein, an equivalent level of safety will be maintained since the DJI Inspire 1 (Model 

T600) UAs are equipped with a barometric pressure sensor and GPS equipment, which 

automatically ensures that a ground level pressure setting will be established prior to each flight, and 

provides the PIC with altitude information of the UA on the heads-up display of the GCS.

4. Extent Of Relief Christian Nowosiadly Seeks And The Reason Christian Nowosiadly 

Seeks Relief From Section 91.151(b).

Relief from Section 91.151(b) entitled Fuel requirements for flight in VFR conditions, is requested 

to the extent required to allow flights of the battery powered DJI Inspire 1 (Model T600) UAs 

during daylight hours in visual meteorological conditions (VMC), under visual flight rules (VFR), for 
a total duration of 13.5 minutes to the first point of intended landing and, assuming normal cruising 

speed, to fly after that for at least 4.5 minutes. Christian Nowosiadly seeks the requested relief 

because without an exemption from Section 91.151(b), the flight time duration of the battery 

powered DJI Inspire 1 (Model T600) UAs will severely constrain the practicality of any aerial video 

or still photo flight operations that Christian Nowosiadly proposes to conduct pursuant to this 

Petition. Significantly, as set forth below, the technical specifications of the DJI Inspire 1 (Model 

T600) UASs, the DJI Inspire 1 (Model T600) operating documents, and Christian Nowosiadly’s 

proposed operating limitations, ensure that Christian Nowosiadly will safely operate the battery 

powered DJI Inspire 1 (Model T600) UAs during daylight hours in visual meteorological conditions 

(VMC), under visual flight rules (VFR), with enough battery power to fly for a total duration of 

13.5 minutes to the first point of intended landing and, assuming normal cruising speed, to fly after 

that for at least 4.5 minutes. 

5. Extent Of Relief Christian Nowosiadly Seeks And The Reason Christian Nowosiadly 

Seeks Relief From Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), And 91.417(a) & 

(b).

Since Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) only apply to 

aircraft with an airworthiness certificate, Christian Nowosiadly requests relief from these Sections 

because the DJI Inspire 1 (Model T600) UASs do not require airworthiness certificates. As set forth 

more fully below, the DJI Inspire 1 (Model T600) UASs meet the conditions of FMRA Section 333 

for operation without an airworthiness certificate. Accordingly, Christian Nowosiadly will use 

trained technicians to perform maintenance, alterations, or preventive maintenance on the UASs 

using the methods, techniques, and practices prescribed in the UAS operating documents (i.e., the 

Christian Nowosiadly Aerial Operations Manual, Monthly Maintenance Log, and DJI Inspire 1 

(Model T600) Professional Instruction Manual). Furthermore, Christian Nowosiadly will document 
and maintain all maintenance records for the DJI Inspire 1 (Model T600) UASs.

D. The Reasons Why Granting Christian Nowosiadly Request Would Be In The Public 

Interest; That Is, How It Would Benefit The Public As A Whole.

Granting the present Petition will further the public interest by allowing Christian Nowosiadly to 

safely, efficiently, and economically perform aerial video and photography of construction sites, real 

estate, and landscape over certain areas of the United States. 

Additionally, use of the DJI Inspire 1 (Model T600) UASs will decrease congestion of the NAS, 

reduce pollution, and provide significant benefits to the economy. Notably, the benefits of 

Christian Nowosiadly's proposed operation of the DJI Inspire 1 (Model T600) UASs will be 

realized without implicating any privacy issues. 

1. The Public Will Benefit From Decreased Congestion Of The NAS.

The DJI Inspire 1 (Model T600) UAs are battery powered and serve as a safe, efficient, and 

economical alternative to the manned aircraft traditionally utilized to obtain aerial imagery. By 

reducing the amount of manned aircraft needed to perform aerial acquisitions, an exemption 

allowing the use of a DJI Inspire 1 (Model T600) UAS would reduce the amount of manned aircraft 

in the NAS, reduce noise and air pollution, as well as increase the safety of life and property in the 

air and on the ground. 

Furthermore, by reducing the number of manned aircraft operating in the NAS, congestion around 

airports caused by arriving and departing aircraft will be reduced. The DJI Inspire 1 (Model T600) 

UAs do not require an airport to takeoff or land. Likewise, a reduction of manned aircraft 

conducting aerial video and photography missions would result in fewer aircraft that must be 

handled by air traffic control during the ground, takeoff, departure, arrival, and landing phases of 

flight operations. 
2. The Public Will Benefit From The Safety And Efficiency Of The DJI Inspire 1 (Model 

T600) UASs.

Conducting aerial acquisitions with the DJI Inspire 1 (Model T600) UASs, instead of manned 

aircraft, will greatly benefit the public by drastically reducing the levels of air and noise pollution 

generated during traditional aerial video and still photography flight operations. By using battery 

power and electric motors, the DJI Inspire 1 (Model T600) UASs produce no air pollution, and is 

the most viable environmentally conscious alternative to the cabin class, six cylinder internal 

combustion engine aircraft that are typically utilized for aerial video and photography, while burning 

approximately 20-30 gallons per hour of leaded aviation fuel. The DJI Inspire 1 (Model T600) UAs, 

while reducing the carbon footprint of aerial acquisitions, also eliminates noise pollution, as the UAs 

are propelled by battery powered electric motors, rather than an internal combustion engine. By 

using the DJI Inspire 1 (Model T600) UASs to perform aerial acquisitions, the substantial risk to life 

and property in the air and on the ground, which is usually associated with traditional manned 

aircraft flight operations, will be substantially reduced or completely eliminated. Aside from the lack 

of flight crew members located onboard the aircraft, the DJI Inspire 1 (Model T600) UAs has less 

physical potential for collateral damage to life and property on the ground, and in the air, compared 

to the manned aircraft that typically conduct similar operations (weighing approximately 6,000 

pounds with a wingspan of approximately 42 feet, a length of 34 feet, and a fuel capacity of 180 

gallons). 

3. Performing Aerial Video and Photography Operations With The DJI Inspire 1 (Model 

T600) UASs Will Benefit The Economy.

In addition to being safe and efficient, the DJI Inspire 1 (Model T600) UASs are also an 

economical alternative to using manned aircraft to conduct similar aerial operations. As such, 

operation of the DJI Inspire 1 (Model T600) UASs will allow United States based companies, like 
Christian Nowosiadly, to remain competitive and contribute to growth of the U.S. economy. 

Specifically, with the rising cost of aviation fuel and the Environmental Protection Agency (“EPA”) 

regulatory actions phasing out leaded aviation fuels, U.S. owned and operated companies must 

adopt new and alternative technology in order to remain competitive. Operating the battery 

powered DJI Inspire 1 (Model T600) UASs is one such technology that not only allows companies 

greater operational flexibility compared to manned aircraft, but provides such flexibility without the 

high operational cost of a traditional manned aircraft. 

By operating the DJI Inspire 1 (Model T600) UASs, companies such as Christian Nowosiadly, can 

remain competitive and profitable, and therefore, provide greater job stability to employees and 

contractors, which will ultimately contribute to growth of the U.S. economy. Improved financial 

performance of U.S. companies, through commercial use of the DJI Inspire 1 (Model T600) UASs, 

provides a stable workforce that increases consumer spending; improves local, state, and federal tax 

revenues; and allows companies to invest in research and development in order to remain 

competitive both in the United States and abroad. 

4. There Are No Privacy Issues.

Similar to the manned aerial acquisition flight operations that have been conducted for decades, 

Christian Nowosiadly's proposed operation of the DJI Inspire 1 (Model T600) UASs will not 

implicate any privacy issues. Specifically, the DJI Inspire 1 (Model T600) UASs will be operated only 

in compliance with operating documents (i.e., the Christian Nowosiadly Aerial Operations Manual, 

Monthly Maintenance Log, and DJI Inspire 1 (Model T600) Instruction Manual) which requires 

property owner involvement as well as local law enforcement notification, and in accordance with 

the Federal Aviation Regulations, including the minimum altitude requirements of 14 C.F.R. § 

91.119. 
E. The Reasons Why Granting The Exemption Would Not Adversely Affect Safety, Or How 

The Exemption Would Provide A Level Of Safety At Least Equal To That Provided By The 

Rule From Which Christian Nowosiadly Seeks Exemption.

1. Reasons Why The DJI Inspire 1 (Model T600) UAs Meet The Conditions Of The 

FAA Modernization and Reform Act of 2012 (FMRA) Section 333.

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

aircraft and its operation, Christian Nowosiadly operation of the DJI Inspire 1 (Model T600) UASs 

meet the conditions of FMRA Section 333, and will not require an airworthiness certificate in 

accordance with 14 C.F.R. Part 21, Subpart H. Section 333 provides authority for a UAS to operate 

without airworthiness certification and sets forth requirements for considering whether a UAS will 

create a hazard to users of the NAS or the public, or otherwise pose a threat to national security. 

Specifically, FMRA Section 333 states the following, in part: 

(a) In General.--Notwithstanding any other requirement of this subtitle, and not later than 180 days 

after the date of enactment of this Act, the Secretary of Transportation shall determine if certain 

unmanned aircraft systems may operate safely in the national airspace system before completion of the 

plan and rulemaking required by section 332 of this Act or the guidance required by section 334 of 

this Act.

(b) Assessment of Unmanned Aircraft Systems.--In making the determination under subsection (a), the 

Secretary shall determine, at a minimum—

(1) which types of unmanned aircraft systems, if any, as a result of their size, weight, 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 national airspace system or the public or pose a

threat to national security; and

(2) whether a certificate of waiver, certificate of authorization, or airworthiness certification under 

section 44704 of title 49, United States Code, is required for the operation of unmanned aircraft 

systems identified under paragraph (1).

(c) Requirements for Safe Operation.--If the Secretary determines under this section that certain 

unmanned aircraft systems may operate safely in the national airspace system, the Secretary shall 

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

In seeking this exemption, Christian Nowosiadly submits that the DJI Inspire 1 (Model T600) UASs 
can operate safely in the NAS pursuant to FMRA Section 333, as demonstrated by: (a) the 

characteristics of the DJI Inspire 1 (Model T600) UASs; (b) the pilot certification requirement; and 

(c) the specific operating limitations. 

a. The Specifications Of The DJI Inspire 1 (Model T600) UASs Demonstrate Its Safe 

Characteristics.

The DJI Inspire 1 (Model T600) UASs do not create a hazard to users of the NAS or the public, or 

otherwise pose a threat to national security considering its size, weight, speed, and operational 

capability. 

i. Technical Specifications Of The DJI Inspire 1 (Model T600) UASs.

The technical specifications of the DJI Inspire 1 (Model T600) UASs are set forth by the DJI 

Inspire 1 (Model T600) Specifications, attached hereto as Exhibit A. 

ii. The DJI Inspire 1 (Model T600) UASs Autonomous Flight And Navigation Modes 

Enable The UASs To Remain Within A Defined Operational Area.

The DJI Inspire 1 (Model T600) UASs may be operated in both manual and fully autonomous flight 

modes. A complete description of the flight and navigational modes of the DJI Inspire 1 (Model 

T600) UASs is provided in the DJI Inspire 1 (Model T600) User Manual, attached hereto as 

Exhibit B. 

iii. The DJI Inspire 1 (Model T600) UASs Are Designed For Automatic Return To Home 

Point Or Hover In The Event Of Loss Of The Control Link Or Navigation.

When the Control Link is lost, the DJI Inspire 1 (Model T600) UAs will remain stationary, in flight, 

for 3 seconds or more. If, after 3 seconds, the DJI Inspire 1 (Model T600) UAs do not reacquire 

control link data from the GCS, the UAs will assume that the Control Link is lost and the UAs will 

return to the home position (i.e., failsafe mode) via GPS, and will descend to the takeoff position 

and shutdown. 
A complete description of the Failsafe Functions of the DJI Inspire 1 (Model T600) UAS are set 

forth in the DJI Inspire 1 (Model T600) User Manual, attached hereto as Exhibit B. 

iv. The DJI Inspire 1 (Model T600) GCS And Its Operation.

A complete description of the operation and specifications of the DJI Inspire 1 (Model T600) GCS 

and flight control software is provided in the DJI Inspire 1 (Model T600) User Manual. 

DJI Inspire 1 (Model T600) User Manual is attached hereto as Exhibit B. 

b. Flight Operations Of DJI Inspire 1 (Model T600) UASs Are Limited To The Line Of Sight 

Of A Pilot in Command With A Safety Observer.

Christian Nowosiadly will only utilize pilots who have at least 20 hours flight time to act as a pilot in 

command (PIC) of the DJI Inspire 1 (Model T600) UASs. Additionally, a safety observer will assist 

all pilots during flight time. 

c. Flights Of DJI Inspire 1 (Model T600) UASs Will Be Conducted Pursuant To Specific 

Operating Limitations.

In seeking this exemption, Christian Nowosiadly proposes to commercially operate DJI Inspire 1 

(Model T600) UASs for the special purpose of conducting aerial video and photography over 

certain areas of United States, pursuant to the following specific operating limitations: 

1. Operations authorized by this grant of exemption will be limited to the following 

aircraft described in the operating documents, rotorcraft UASs weighing less 

than 55 pounds maximum gross weight: DJI Inspire 1 (Model T600) Unmanned 

Aircraft Systems. Proposed operations of any other aircraft will require a new

petition or a petition to amend this grant. 

2. UAS operations under this exemption will be limited to conducting operations 

for the purpose of aerial video and photography. 

3. The UAs may not be flown at an indicated airspeed exceeding 20 knots. 

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

(AGL), as indicated by the procedures specified in the operating documents unless a

special request is made and approved by ATC. All altitudes reported to ATC must be 

in feet AGL. 

5. The UAs 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. 

6. The use of first person view (FPV) by the PIC or safety observer (SO) is not 

permitted. 

7. All operations must utilize a safety observer (SO). The SO may be used to satisfy the 

VLOS requirement as long as the PIC always maintains VLOS capability. The SO 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 SO can perform the functions 

prescribed in the operating documents. 

8. The SO must not perform any other duties beyond assisting the PIC with seeing and 

avoiding other air traffic and other ground based obstacles/obstructions and is not 

permitted to operate the camera or other instruments. 

9. The operating documents and the grant of exemption must be accessible during UAS 

operations and made available to the Administrator upon request. If a discrepancy 

exists between the conditions and limitations contained in the grant of exemption and 

the procedures outlined in the operating documents, the conditions and limitations 

contained in the grant of exemption 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 upon request. The operator must also 

present updated and revised documents if it petitions for extension or amendment to the

grant of exemption. If the operator determines that any update or revision would affect 

the basis upon which the FAA granted the exemption, then the operator must petition 

for 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. 

10. Prior to each flight the PIC must inspect the UAS to ensure that it is in a condition for 

safe flight. 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. The Ground 

Control Station must be included in the preflight inspection. All maintenance and 

alterations must be properly documented in the aircraft records. 

11. 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. The PIC who conducts the functional test 

flight must make an entry in the aircraft records. 

12. The pre-flight inspection must account for all potential discrepancies, e.g. inoperable 

components, items, or equipment, not already covered in the relevant sections of the 
operating documents. 

13. The operator must follow the UAS manufacturer’s aircraft/component, 

maintenance, overhaul, replacement, inspection, and life limit requirements. 

14. The operator must carry out its maintenance, inspections, and record keeping

requirements, in accordance with the operating documents. Maintenance, inspection, 

alterations, and status of replacement/overhaul component parts must be noted in the 

aircraft records, including total time in service, description of work accomplished, and 

the signature of the authorized person returning the UAS to service. 

15. Each UASs operated under this exemption must comply with all manufacturer Safety 

Bulletins. 

16. The authorized person must make an entry in the aircraft record of the corrective 

action taken against discrepancies discovered between inspections. 

17. The PIC must have completed at least 25 hours of flight time. 

18. The operator may not permit any PIC to operate unless the PIC meets the operator’s 

qualification criteria and demonstrates the ability to safely operate the UAS in a manner 

consistent with how the UAS will be operated under the exemption, including evasive

and emergency maneuvers and maintaining appropriate distances from persons, vessels, 

vehicles and structures. PIC qualification flight hours must be logged in a manner 

consistent with 14 C.F.R. § 61.51(b). Flights for the purposes of training the operator’s 

PICs are permitted under the terms of the 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 C.F.R. § 91.119. 

19. UAS operations may not be conducted during night, as defined in 14 C.F.R. § 1.1. All 

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

at night is required, a special request will be made at the FAA office closest to proposed 

area of operations. Flights under special visual flight rules (SVFR) are not authorized. 

20. The UA may not operate within 2 nautical miles of an airport reference point as denoted 

on a current FAA-published aeronautical chart unless a letter of agreement with that 

airport’s management is obtained, and the operation is conducted in accordance with a 

NOTAM as required by the operator’s COA. The letter of agreement with the airport 

management must be made available to the Administrator upon request.

21. The UA may not be operated less than 400 feet below or less than 2,000 feet 

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

22. If the UA loses communications or loses its GPS signal, it must return to a 

predetermined location within the planned operating area and land or be recovered in 

accordance with the operating documents. 
23. The PIC must abort the flight in the event of unpredicted obstacles or emergencies in 

accordance with the operating documents. 

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

weather conditions) there is enough power to fly at normal cruising speed to the

intended landing point and land the UA with 25% battery power remaining. 

25. The operator must obtain an Air Traffic Organization (ATO) issued Certificate of 

Waiver or Authorization (COA) prior to conducting any operations under the grant of 

exemption. This COA will also require the operator to request a Notice to Airman 

(NOTAM) not more than 72 hours in advance, but not less than 48 hours prior to the 

operation. All operations shall be conducted in accordance with airspace requirements in 

the ATO issued COA including class of airspace, altitude level and potential transponder 

requirements. 

26. All aircraft operated in accordance with the exemption must be identified by serial 

number, registered in accordance with 14 C.F.R. part 47, and have identification (NNumber) markings in accordance with 14 C.F.R. part 45, Subpart C. Markings must be 

as large as practicable. 

27. Before conducting operations, the radio frequency spectrum used for operation and 

control of the UA must comply with the Federal Communications Commission (FCC) 

or other appropriate government oversight agency requirements. 

28. The documents required fewer than 14 C.F.R. 91.9 and 91.203 must be available to the 

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

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

official upon request. 

29. The UA must remain clear and yield the right of way to all manned aviation 

operations and activities at all times. 

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

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

persons (persons other than the PIC, SO, operator trainees or essential 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 and/or; 

b. The aircraft is operated near vessels, vehicles or structures where the 

owner/controller of such vessels, vehicles or structures has granted 

permission 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, and; 
c. Operations nearer to the PIC, SO, operator trainees or essential persons do 

not present an undue hazard to those persons per § 91.119(a). 

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

permission from the land owner/controller or authorized representative. Permission 

from land owner/controller or authorized representative will be obtained for each 

flight to be conducted. 

33. 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. 

2. Reasons Why An Exemption From The Requirements Of Section 61.113(a) And (b) Would 

Not Adversely Affect Safety.

Christian Nowosiadly submits that the equivalent level of safety established by Section 61.113(a) and 

(b) will be maintained because no PIC will be allowed to operate the DJI Inspire 1 (Model T600) 

UASs unless that PIC has demonstrated, by meeting minimum flight-hour and currency

requirements, that the PIC is able to safely operate the DJI Inspire 1 (Model T600) UAS in a manner 

consistent with the exemption, including evasive and emergency maneuvers and maintaining 

appropriate distances from people, vessels, vehicles and structures. Considering Christian 

Nowosiadly's proposed area of operations, and the operating limitations set forth-above; the parallel 

nature of aeronautical knowledge requirements to those of commercial pilot requirements (See 

Exemption No. 11062); and the airmanship skills necessary to safely operate the DJI Inspire 1 

(Model T600), Christian Nowosiadly submits that the additional manned airmanship experience of a 

commercially certificated pilot would not correlate to the airmanship skills necessary for Christian 

Nowosiadly's specific proposed flight operations. 

The FAA has previously granted relief from Section 61.113(a) and (b) specific to UAS, in 

circumstances similar, in all material respects, to those presented herein (e.g. Exemption Nos. 11062, 

11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112, 11136, 11138, 11150, 11153, 
11156, 11158, 11159, 11160, 11161). 

Christian Nowosiadly will not allow any PIC to operate the DJI Inspire 1 (Model T600) UAS unless 

that PIC has demonstrated, by meeting minimum flight-hour requirements or the DJI Inspire 1 

(Model T600) UAS training and currency requirements, that the PIC is able to safely operate the DJI 

Inspire 1 (Model T600) UAS in a manner consistent with this exemption, including evasive and 

emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles and 

structures. 

Specifically, the PIC must have accumulated and logged, in a manner consistent with 14 C.F.R. § 

61.51(b), 25 hours of total time as a UAS rotorcraft pilot (with a minimum of 5 hours of those hours 

as a UAS pilot operating the same make and model of UAS to be used for operations under the 

exemption). In addition to the hour requirements, the PIC must accomplish 3 takeoffs and landings 

in the preceding 90 days (for currency purposes). 

As in Exemption Nos. 11062, 11138, and 11153, prior documented flight experience that was 

obtained in compliance with applicable regulations will ensure an equivalent level of safety during 

Christian Nowosiadly's proposed operations. The Administrator has held that prior documented 

flight experience that was obtained in compliance with applicable regulations would ensure safe 

operations, stating as follows: 

In Exemption No. 11062, the FAA required that prior to conducting operations for the purpose of 

motion picture filming (or similar operations), the PIC must have accumulated and logged, in a 

manner consistent with 14 CFR 61.51(b), 25 hours of total time as a UAS rotorcraft pilot including 

at least 10 hours logged as a UAS pilot with a multi-rotor UAS. Prior to operations under 
Exemption No. 11062, the PIC must also have accumulated and logged a minimum of 5 hours as a 

UAS pilot operating the same make and model of UAS to be used for operations under the 

exemption. For clarification, the FAA considers these minimum hour requirements to be inclusive 

rather than additive; i.e. 5 hours make and model time may be included in the 10 hours of multirotor time and the 10 hours may be included in the total 25 hours of UAS rotorcraft time. In 

addition to the hour requirements, the PIC must accomplish 3 takeoffs and landings in the

preceding 90 days (for currency purposes). The FAA finds that at a minimum, the flight-hour 

requirements in Exemption No. 11062 are appropriate to practice and build proficiency in the 

skills necessary to safely conduct the petitioner’s proposed operations. The FAA also finds that prior 

documented flight experience that was obtained in compliance with applicable regulations would 

satisfy this requirement. Training, proficiency, and experience-building flights can also be conducted 

under the grant of exemption to accomplish the required flight time. During training, proficiency, 

and experience-building flights the PIC is required to operate the UA with appropriate distances in 

accordance with 14 C.F.R 91.119. Exemption No. 11138 at page 15. 

Accordingly, Christian Nowosiadly will ensure safe operations by not allowing any PIC to operate 

the DJI Inspire 1 (Model T600) UAS unless that PIC has demonstrated, by meeting minimum 

flight-hour and currency requirements, that the PIC is able to safely operate the DJI Inspire 1 

(Model T600) UAS in a manner consistent with the exemption, including evasive and emergency 

maneuvers and maintaining appropriate distances from people, vessels, vehicles and structures. 

3. Reasons Why An Exemption From The Requirements Of Section 91.7(a) Would Not 

Adversely Affect Safety.

The equivalent level of safety established by Section 91.7(a) will be maintained because prior to 

every flight, Christian Nowosiadly will ensure that the DJI Inspire 1 (Model T600) UAS is in an 

airworthy condition based upon the UAS’s compliance with its operating documents and as 
stated in the conditions and limitations herein. Additionally, the FAA has previously granted 

relief from Section 91.7(a) specific to UAS, in circumstances similar, in all material respects, to 

those presented herein (e.g. Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 

11109, 11110, 11112, 

11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161). 

4. Reasons Why An Exemption From The Requirements Of Section 91.121 Would Not 

Adversely Affect Safety.

The equivalent level of safety established by Section 91.121 will be maintained because the altitude 

information of the DJI Inspire 1 (Model T600) UAs will be provided to the PIC via GPS 

equipment and a radio communications telemetry data link, which downlinks from the UA to the 

GCS for active monitoring of the flight path and altitude. This altitude information, combined with 

Christian Nowosiadly's operation of the DJI Inspire 1 (Model T600) UAs within visual line of 

sight, at or below 400 feet AGL, will ensure a level of safety equivalent to Section 91.121. The 

altitude information will be generated by GPS equipment installed onboard the aircraft. Prior to 

each flight, a zero altitude initiation point is automatically established by the UASs at ground level. 

The FAA has previously granted relief from Section 91.121 specific to UAS, in circumstances 

similar, in all material respects, to those presented herein (e.g. Exemption Nos. 11062, 11063, 11064, 

11065, 11066, 11067, 11080, 11109, 11112, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 

11159, 11160, 11161). 

5. Reasons Why An Exemption From The Requirements Of Section 91.151(b) Would Not 

Adversely Affect Safety.

A grant of this exemption would ensure an equivalent level of safety established by 14 C.F.R. 

Section 91.151(b) as a result of (1) the technical specifications of the DJI Inspire 1 (Model T600) 

UASs; (2) the limitations on the proposed flight operations; and (3) the location of the proposed 

flight operations. Accordingly, Christian Nowosiadly will ensure that it will safely operate the battery 
powered DJI Inspire 1 (Model T600) UAs during daylight hours in VFR conditions, with enough 

battery power to fly for a total duration of 13.5 minutes to the first point of intended landing and, 

assuming normal cruising speed, to fly after that for at least 4.5 minutes. 

Here, as in Exemption No. 11109, the technical specifications of the DJI Inspire 1 (Model T600) 

UASs; the limitations on the proposed flight operations; and the location of the proposed 

operations, will ensure an equivalent level of safety established by 14 C.F.R. Section 91.151(b). 

Furthermore, safety will be ensured as the DJI Inspire 1 (Model T600) UASs provide audible and 

visual warnings to the PIC at the GCS when the UAs experiences low battery voltage, the first 

warning occurring at approximately 33% remaining battery power, and again at approximately 10% 

remaining battery power. At the critically low battery level, the DJI Inspire 1 (Model T600) UASs 

will descend and land automatically. 

Significantly, previous exemptions granted by the FAA concerning Section 91.151 establish that 

safety is not adversely affected when the technical characteristics and operating limitations of the 

UAS are considered. Relief has been granted for manned aircraft to operate at less than the 

minimums prescribed in Section 91.151, including Exemption Nos. 2689, 5745, and 10650. 

Moreover, the FAA has previously granted relief from Section 91.151 specific to UAS, in 

circumstances similar, in all material respects, to those presented herein (e.g. Exemption Nos. 8811, 

10808, 10673, 11042, 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11136, 

11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161). 

6. Reasons Why An Exemption From The Requirements Of Sections 91.405(a), 91.407(a)(1), 

91.409(a)(1) & (a)(2), And 91.417(a) & (b) Would Not Adversely Affect Safety.

In seeking this exemption, Christian Nowosiadly submits that the equivalent level of safety with 

regard to the regulatory maintenance and alteration requirements established by Sections 

91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) will be met because Christian 
Nowosiadly will use trained technicians to perform maintenance, alterations, or preventive 

maintenance on the UASs using the methods, techniques, and practices prescribed in the 

operating documents (i.e., the Christian Nowosiadly Aerial Operations Manual, Monthly 

Maintenance Log, and DJI Inspire 1 (Model T600) Instruction Manual). Furthermore, Christian 

Nowosiadly will document and maintain all maintenance records for the DJI Inspire 1 (Model 

T600) UASs. 

Since the DJI Inspire 1 (Model T600) UASs will be inspected as prescribed by the operating 

documents, Christian Nowosiadly will maintain the equivalent level of safety established by 

Sections 91.405(a), 91.409(a)(1), and 91.409(a)(2). A copy of the DJI Inspire 1 (Model T600) User 

Manual is attached hereto as Exhibit B; a copy of the DJI Inspire 1 (Model T600) UAS 

Maintenance LOG is attached hereto as Exhibit C. 

Likewise, the exemption sought will not adversely affect safety because Christian Nowosiadly will 

use trained technicians to perform maintenance, alterations or preventive maintenance on the UAS 

using the methods, techniques, and practices prescribed by the operating documents. 

Furthermore, the exemption sought would maintain an equivalent level of safety established by 

Sections 91.407, 91.417(a) and 91.417(b), because all maintenance of the DJI Inspire 1 (Model 

T600) UASs will be performed by trained technicians. Maintenance will be documented and 

maintained utilizing the monthly maintenance log. 

Significantly, previous exemptions granted by the FAA concerning Sections 91.405(a), 91.407(a)(1), 

91.409(a)(1) & (a)(2), and 91.417(a) & (b) establish that safety is not adversely affected when the 

technical characteristics and operating limitations of the UAS are considered.

In consideration of Christian Nowosiadly's proposed operating limitations, the operating 

documents, and the technical aspects of the DJI Inspire 1 (Model T600) UASs, Christian 

Nowosiadly submits that safety will not be adversely affected by granting exemption from 14 C.F.R. 

Sections 91.405(a), 91.407(a)(1) and (a)(2), 91.409(a)(2), and 91.417(a) and (b). The FAA has 
previously granted relief specific to UAS in circumstances similar, in all material respects, to those 

presented herein (e.g. Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 

11110, 11112, 11136, 11138, 11150, 11153, 

11156, 11157, 11158, 11159, 11160, 11161). 

7. The FAA May Prescribe Any Other Conditions For Safe Operation.

In accordance with Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA) and 14 

C.F.R. § 21.16 entitled Special Conditions, Christian Nowosiadly requests that the FAA prescribe 

special conditions for the intended operation of the DJI Inspire 1 (Model T600) UASs, which 

contain such safety standards that the Administrator finds necessary to establish a level of safety 

equivalent to that established by 14 C.F.R. Part 21, Subpart H, and 14 C.F.R §§ 61.113(a) & (b), 91.7 

(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b). Such special 

conditions will permit safe operation of the UAs for the limited purpose of conducting aerial video 

and photography over certain areas of the United States for compensation or hire. FMRA Section 

333 sets forth the requirements for considering whether a UAS will create a hazard to users of the 

NAS or the public, or otherwise pose a threat to national security; and further, provides the 

authority for such UAS to operate without airworthiness certification in accordance with any 

requirements that must be established for the safe operation of the UAS in the NAS. 

Likewise, the Administrator may prescribe special conditions pursuant to 14 C.F.R. § 21.16, for 

operation of the DJI Inspire 1 (Model T600) UASs, since the airworthiness regulations of 14 C.F.R. 

Part 21 do not contain adequate or appropriate safety standards, due to the novel or unusual design 

features of the aircraft. Section 21.16, entitled Special Conditions, states the following: 

If the FAA finds that the airworthiness regulations of this subchapter do not contain adequate or 

appropriate safety standards for an aircraft, aircraft engine, or propeller because of a novel or 
unusual design feature of the aircraft, aircraft engine or propeller, he prescribes special conditions and 

amendments thereto for the product. 

The special conditions are issued in accordance with Part 11 of this chapter and contain such safety standards for 

the aircraft, aircraft engine or propeller as the FAA finds necessary to establish a level of safety equivalent to that 

established in the regulations. See 14 C.F.R. § 21.16. 

Therefore, in accordance with FMRA Section 333 and 14 C.F.R. § 21.16, the FAA may prescribe special 

conditions for Christian Nowosiadly’s intended operation of the DJI Inspire 1 (Model T600) UASs, which 

contain such safety standards that the Administrator finds necessary to establish a level of safety equivalent to 

that established by 14 C.F.R. Part 21, Subpart H, and 14 C.F.R Sections 61.113(a) & (b), 91.7(a), 91.121, 

91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b). 

F. A Summary That Can Be Published In The Federal Register, stating: The Rules From Which 

Christian Nowosiadly Seeks Exemption:

Christian Nowosiadly seeks exemption from the requirements of 14 C.F.R Sections 61.113(a)&(b), 91.7(a), 91.121, 

91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b).

A Brief Description Of The Nature Of The Exemption Christian Nowosiadly Seeks:

This exemption will permit Christian Nowosiadly to commercially operate an Unmanned Aircraft System (UAS) for the 

purpose of conducting aerial video and photography over certain areas of the United States.

G. Any Additional Information, Views, Or Arguments Available To Support Christian Nowosiadly's 

Request.

This Petition is made pursuant to the FAA Modernization and Reform Act of 2012 (FMRA) Section 333, which 

directs the Secretary of Transportation to determine if certain UAS may operate safely in the NAS. As such, 

Christian Nowosiadly's request for exemption may be granted pursuant to the authority of FMRA Section 333 

and 14 C.F.R. Part 11, as set forth above. 

FMRA Section 333 sets forth the requirements for considering whether a UAS will create a hazard to users of 

the NAS or the public, or otherwise pose a threat to national security; and further, provides the authority for 
such UAS to operate without airworthiness certification. 

As discussed in detail above, Christian Nowosiadly will operate the DJI Inspire 1 (Model T600) UASs safely in the 

NAS, without creating a hazard to users of the NAS, or the public, or otherwise pose a threat to national security. 

CONCLUSION

As set forth herein, Christian Nowosiadly seeks an exemption pursuant to 14 C.F.R. § 11.61 and Section 333 of 

the FAA Modernization and Reform Act of 2012 (FMRA), which will permit safe operation of the DJI Inspire 1 

(Model T600) UASs commercially, without an airworthiness certificate, for the limited purpose of conducting 

aerial video and photography over certain areas of the United States. By granting this Petition, the FAA 

Administrator will be fulfilling the Congressional mandate of the FAA Modernization and Reform Act of 2012, 

while also advancing the interests of the public, by allowing Christian Nowosiadly to safely, efficiently, and 

economically operate the DJI Inspire 1 (Model T600) UASs commercially within the NAS. 

WHEREFORE, in accordance with the Federal Aviation Regulations and the FAA Modernization and Reform 

Act of 2012, Section 333, Christian Nowosiadly respectfully requests that the Administrator grant this Petition 

for an exemption from the requirements of 14 C.F.R Sections 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 

91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b), and 

permit Christian Nowosiadly to operate the DJI Inspire 1 (Model T600) UASs commercially for the purpose of 

conducting aerial video and photography over certain areas of the United States. 

Dated: September 22nd, 2015 Respectfully submitted, Christian 

Nowosiadly 

45 Leyden St 

Boston, MA 02128 

Email: christian@nowcitytours.com
Appendices: 

A – DJI Inspire 1 (Model T600) Specifications Data Sheet 

B – DJI Inspire 1 (Model T600) Manufacturer’s User Manual Link 

C – Monthly Maintenance Log 

APPENDIX – A 

DJI Inspire 1 (Model T600) TECHNICAL SPECIFICATIONS

Christian Nowosiadly only utilizes safe and reliable UASs. DJI is an industry leader in small UAS 

production. DJI UASs are loaded with ground breaking software enabling the user to set parameters 

which will not allow flight into controlled airspace. Parameters can also be set to limit flight to no 

higher than a predetermined and set altitude as well as limit flight to a predetermined and set 

distance. In addition, DJI software provides real-time altitude and location information to the PIC 

via the linked monitor (smart phone/tablet devices) 

1.1.1 DJI Inspire 1 (Model T600)

1.1.2 Aircraft 

1.1.2.1 Supported Battery – DJI 4500mAH LiPo Battery 

1.1.2.2 Weight (Battery & Propellers Included) – 1.25 pounds 

1.1.2.3 Hover Accuracy (Ready to Fly) – Vertical: 0.5m; Horizontal: 2..5m 

1.1.2.4 Max Flight time - Approximately 18 minutes 

1.1.2.5 Max Tilt Angel - 350 

1.1.2.6 Max Ascent Speed – 5m/s 

1.1.2.7 Max Descent Speed – 4m/s 

1.1.2.8 Max Flight Speed – 22m/s (NOT RECOMMENDED) 

1.1.2.9 Operating Temperature - 10oC - 40oC 

1.1.2.10 Max Flight Altitude - 4500m 

1.1.2.11 GPS Mode - GPS/GLONASS 

1.1.2 Gimbal 

1.1.2.1 Controllable Range – Pitch: -900 +300 

1.1.3 Camera 

1.1.3.1 Sensor - Sony EXMOR 1/2.3" 

1.1.3.2 Lens - FOV 94o 20mm (35mm format equivalent) f/2.8 

1.1.3.3 Effective Pixels – 12.4M 

1.1.3.4 Resolution – 4384x3288 

4.1.3.5 HD Video Recording – 4K, 1080p & 720p 

4.1.3.6 Image Max Size - 4000 x 3000 

1.1.4 Remote Controller 

1.1.4.1 Operating Frequency – 2.400GHz – 2.483GHz 

1.1.4.2 Communication Distance (unobstructed) – 2km 

1.1.4.3 Battery - 5700 mAh LiPo 2s 

1.1.4.4 Transmitter Power – FCC: 20dbm CE: 16 dbm 

1.1.4.5 Working Voltage – 1.2 A @7.4 V 
APPENDIX – B 

DJI Inspire 1 (Model T600) Manufacturer’s User Manual is too large to submit, however a link to 

this information is: 

http://download.djiinnovations.com/downloads/inspire_1/en/Inspire_1_User_Manual_v1.4_en.pdf
APPENDIX – C 

Maintenance Log: Date: 

UAS # Date Issue 

Discovered 

Date Issue 

Addressed Issue Description Peron Competed