UNITED STATES OF AMERICA

DEPARTMENT OF TRANSPORTATION

FEDERAL AVIATION ADMINISTRATION

WASHINGTON, DC

FOR	AN	EXEMPTION	SEEKING	RELIEF	FROM	THE	REQUIREMENTS	OF

TITLE	14	OF	THE	CODE	OF	FEDERAL	REGULATIONS

SECTIONS	61.113(a),	61.23	(a)	&	(c),	91.7(a),	91.119	(c),	91.121,	

91.151(a)(1)	&(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 UNMANNED	AIRCRAFT SYSTEM

PURSUANT	TO	SECTION	333	OF

THE	FAA	MODERNIZATION	AND	REFORM	ACT	OF	2012

(PUBLIC	LAW	112-95)

Contact Information:

John D. Henley II

UCay, Inc.

DBA: Skyhawk Videos & Photography 

12520 Westheimer Rd., #A1-228

Houston, TX, 77077-5861

Tel: (832)894-9176

Email: skyhawkvideos@gmail.com June 10, 2015
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INTRODUCTION & OPERATION OF BUSINESS

I, John D. Henley II, am requesting in pursuant to Section 333 of FAA Modernization and 

Reform Act of 2012 an exemption from the requirements of 14 C.F.R §§ 61.113(a),	61.23	(a)	&	

(c),	91.7(a),	91.119	(c),	91.121,	91.151(a)(1)	& (b),	91.405(a),	91.407(a)(1), 91.409(a)(1)	&	

(a)(2),	AND	91.417(a)	&	(b). As a small business owner of UCay, Inc. with a DBA: Skyhawk 

Video & Photography, this exemption will allow me to provide quality and cost efficient 

services to my clients by providing aerial photography using an Unmanned Aircraft System for 

commercial and residential purposes. The video and photography scope of my business covers:

 real estate

 construction

 special events

 film production

 urban development

 education

Equipment

Skyhawk Video & Photography is requesting an exemption to operate a DJI Inspire 1 as a sales 

tool for compensation & hire to be used within the National Airspace System. The DJI Inspire 1, 

Model T600 is a vertical takeoff and landing Unmanned Aircraft System with a Ground Control 

Station utilizing electronic tablet or smart phone systems. The DJI Inspire 1 is a brand new 

quadcopter capable of capturing 4K video and transmitting an HD video signal (up to 2km) to 

multiple devices straight out of the box. Equipped with retractable landing gear, it can capture an 

unobstructed 360 degree view from its camera. The built-in camera has an integrated gimbal to 

maximize stability and weight efficiency while minimizing space. When no GPS signal is 

available, Vision Positioning technology provides hovering precision. The DJI Inspire 1 has the 

following specifications:

 maximum gross weight 2935 grams

 dimensions – 438x451x301 mm

 maximum ascent speed – 5 m/s

 max descent speed – 4 m/s
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 max speed – 22 m/s (ATTI, no wind)

 max flight altitude – 4500 m

 max flight time – approx 18 minutes

 velocity range – below 8 m/s (2m above ground)

 altitude range - 5-500 cm

Remote Controller

Specification for the radio control equipment:

 Operating frequency 5.725- 5.825GHz & 2.400-2.483GHz

 Transmitting Distance 2 km

 EIRP 10dBm@900m, 13dBm@5.8G, 20dBm@2.4G

 Battery 6000 mAh LiPo 25

The DJI Inspire 1 is also equipped with four main rotors, motor model DJI 3510; driven by

Lithium Polymer high voltage battery; remote controller and a 12.76 m/p video camera.

OPERATION OF EQUIPMENT

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

and limitations: Pilot in command, is requested to the extent necessary that it is to be allow that a 

Pilot in Command (PIC) holding a private pilot will be in command of this UAS, and who has 

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

to safely operate the DJI Inspire 1 in a manner consistent with this exemption, including evasive 

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

and structures. 

AIRCRAFT WORTHNESS 

Skyhawk Video & Photography request exemption from Section 91.7(a), entitled Civil aircraft 

airworthiness, because in accordance with 14 C.F.R. Part 21, Subpart H the DJI Inspire 1 does 

not require to have airworthiness certification. (Section 91.7). In so saying Skyhawk Video & 

Photography do undertake that it will ensure that the UAS be maintained in an airworthy 
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condition, prior to every flight, by determining that the UASs are in compliance with the 

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

and that the aircraft are in a condition for safe flight. (Section 91.9). 

SPEED, WEIGHT, SIZE AND LIMITED OPERATING AREA

With relevance to the speed, weight, size, and limited operating area associated with the 

unmanned aircraft and its operation, the DJI Inspire 1 meets the conditions of FAAMRC Section 

333 and therefore, will not require an airworthiness certificate in accordance with 14 C.F.R. Part 

21, Subpart H. Accordingly, we hereby request 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.

Exemption of Section 91.121

Skyhawk Video & Photograpy hereby request exemption from the requirement of Section 

91.121, entitled Altimeter Settings for the DJI Inspire 1 do not have a typical barometric altimeter 

on board the equipment.

Exemption of Section 91.151

Skyhawk Video & Photograpy hereby request exemption from the requirement of Section 

91.121, entitled Fuel Requirements for Flight in VFR Conditions for the DJI Inspire 1 do not 

have a typical barometric altimeter on board the equipment.

In accordance with 14 C.F.R. Section 11.81, I hereby provide the following information in 

support of this petition for exemption:

Name and address of the Petition:

John D. Henley II

UCay, Inc.

DBA: Skyhawk Video & Photography

12520 Westheimer Rd. A-1 #228

Houston, TX 77077-5861 

Tel: (281)849-4060
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UNMANNED AIRCRAFT PIC

In addition to holding a private pilot licence certification and FAR61.31F endorsement since 

1997 I, John D. Henley II have extensive experience in flying a UAS on a recreational basis 

since 2013 and during this time I have exercise safety protocols and controls of the aircraft in 

order to prevent hazard or catastrophe to the general public while being in compliance with the 

regulations of the FAA and the National Airspace System. As record keeping for sharing with 

the FAA the DJI Inspire 1 maintain an internal recording system. This next generation flight 

controller system provides a more reliable flight experience. A new flight recorder stores the 

flight data from each flight, and Vision Positioning enhances hovering precision when no GPS is 

available.

PROPOSED OPERATION OF EQUIPMENT

It is the intention of Skyhawk Videos & Photography to utilize this UAS for the purpose of 

recreational use and for the following commercial & residential use for compensation and hire as 

it is approved under the regulation of these exemption requirements of the FAA. This business 

will be conducted mainly in the State of Texas. These areas of flight are as follows:

(a) Video filming by air and photographing for public and private purposes, including: 

television, cinematography, advertising or promotions. Filming and Photography will 

only be conducted with permission and under contract with registered owners or with 

any local government authority and only when safe to do so. 

(b) Video filming by air and photographing to support professional operations in 

engineering, land surveying and development, architecture, real estate and other 

related professional activities. Filming and Photography will only be conducted with 

permission and under contract with registered owners or with any local government 

authority and only when safe to do so. 
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(c) Inspection by air of infrastructure such as bridges, highways, photovoltaic power 

stations, and pipelines. These inspections will only be done under contract and 

permission with any registered owners or with any local government authority and 

only when safe to do so. 

(d) Inspection by air of land and residential, commercial and industrial structures, only 

under contract and permission with any registered owners or with any local 

government authority and only when safe to do so. 

(e) Support provided to search and rescue operations and reconnaissance in cases of 

need, emergency or natural disasters only when government authorities have 

requested it by contract or donation and only when safe to do so.

(f) Information and technical support for educational purpose.

PUBLIC BENEFIT

The DJI Inspire 1 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 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 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.

Operational Restriction

DJI Inspire 1 Operational Manual and the Safety Guidelines (See attached DJI Inspire 1 

Operational Manual and Safety Guidelines) contain all of the safety and operational procedures 
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and limitations deem necessary to responsibly perform the operations specified in this Petition 

for Exemption.

Relevant Statutory Authority

This Petition for Exemption is submitted pursuant to Section 333(a) through (c) of the FAA 

Modernization and Reform Act of 2012 ("Reform Act"). Congress has directed the FAA "to 

safely accelerate the integration of civil unmanned aircraft systems into the national airspace 

system." Pursuant to Section 333 of the Reform Act, the FAA Administrator is to permit 

unmanned aircraft systems to operate in the National Air Space ("NAS") where it is safe to do so 

based on the following considerations: 

 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 the visual line of sight of the operator. Additionally, the 

FAA 

Administrator has general authority to grant exemptions from the agency's safety regulations and 

minimum standards when the Administrator decides a requested exemption is in the public 

interest. See 49 U.S.C. § 106(f) (defining the authority of the Administrator); 49 U.S.C. § 

44701(f) (permitting exemptions from§§ 44701(a), (b) and§§ 44702-44716, et seq.). A party 

requesting an exemption must explain the reasons why the exemption: (1) would benefit the 

public as a whole, and (2) would not adversely affect safety (or how it would provide a level of 

safety at least equal to the existing rules). See 14 C.F.R. § 11.81 (petitions for exemption). 

These proposed UAS operations meet the Requirements of Section 333 of the Reform Act The 

proposed operations in this Petition for Exemption qualify for expedited approval pursuant to 

Section 333 of the Reform Act as each of the statutory criteria and relevant factors are satisfied. 

Approval is also warranted based on the UAS Size, Weight, Speed, and Operational Capability.

Additionally, approval is warranted based on the 0perational restrictions as it is set forth in the 

operations manual. 
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To Be Publish in the Federal Register

SUMMARY OF EXEMPTION OF 14 C.F.R

1. Skyhawk Video & Photography seeks exemption from the requirements of §61.113 (a). 

Private pilot privileges and limitations: Pilot in command.

Pursuant to 14 C.F.R. 61.113 I, John Henley II do hold a valid Private Pilot license and that I will 

be the Pilot in command for the operation of the DJI Inspire 1. As Pilot in Command I hereby 

agree to safely operate the DJI Inspire 1 in a manner consistent with the exemption, including 

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

vehicles and structures.

2. Skyhawk Video & Photography seeks exemption from the requirements of §61.23 (a) 

& (c). Medical certificates: Requirement and duration.

The medical requirements based on Medical Certificate requirements outlined in the FARs (14 

CFR 61.23). Given the size and weight of 6.47 pounds, the DJI Inspire 1, its structure, the 

limited flight area, and the safety features integrated in the autopilot (among others the Flight 

Termination System), we believes that an Equivalent Level of Safety can be reached if the PIC

has a valid driver’s license.

3. Skyhawk Video & Photography seeks exemption from the requirements of §91.7 (a)

Civil aircraft airworthiness.

Pursuant to 14 C.F.R. §91.7 (a) I, John Henley II hereby agree to ensure that the DJI Inspire 1 

used by Skyhawk Video Photography will be maintain in an airworthy condition prior to any and 

all flight of the equipment. 

4. Skyhawk Video & Photography seeks exemption from the requirements of §91.9 (b)(2)

Civil aircraft flight manual, marking, and placard requirements.

Pursuant to 14 C.F.R. §91.9 the DJI Inspire 1 as a UAS will be operated and maintained in 

accordance with the instruction operational manual of the equipment. The equipment will be 

marked with the identification of ownership as being Skyhawk Video and Photography.
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5. Skyhawk Video & Photography seeks exemption from the requirements of §91.119 (c)

Minimum safe altitudes: General.

Pursuant to maintaining safe altitudes I, John Henley II, hereby attest that in adhering to the FAA 

regulations the DJI Inspire 1 being operated by Skyhawk Videos and Photography, will not be 

operated at an excess legal height of 400 feet.

6. Skyhawk Video & Photography seeks exemption from the requirements of §91.121

Altimeter settings.

Pursuant to the Altimeter settings of the DJI Inspire 1, the equivalent level of safety as 

established in this section will be adhered to by this exemption. In monitoring the altitude 

information this will be generated by the GPS equipment installed onboard the aircraft. 

Exemption is being requested based on the requirements and specification of the DJI Inspire 1.

7. Skyhawk Video & Photography seeks exemption from the requirements of §91.151 (a) 

(1) & (b) Fuel requirements for flight in VFR conditions.

Further to the power operation of the DJI Inspire 1, fuel is not required for flying the UAS, 

instead a 6000 mAh LiPo 25 battery is used for the operation of the UAS. Therefore, I John 

Henley II will hereby ensure that prior to the commencement of each flight there will be 

sufficient battery power for the intended flight time with a minimum of 3 minutes remaining. 

Additionally, each battery have an estimated flight time of approximately 18 minutes flight time 

which allow each of my flights to be for approximately 15 minutes.

8. Skyhawk Video & Photography seeks exemption from the requirements of §91.405 (a)

Maintenance required; §91.407 (a)(1) Operation after maintenance, preventive 

maintenance, rebuilding, or alteration; §91.409 (a)(1) and (2) Inspections and §91.417

(a) and (b) Maintenance records.

Further to previous exemptions granted by the FAA concerning these sections it was established 

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

of the UAS are considered. As these Regulations apply only to aircrafts with an airworthiness 

certificate and not to UAS – DJI Inspire 1, an exemption is being requested for these sections. 

However, I John Henley II hereby undertake that prior to each flight of the UAS a maintenance 

inspection will be done to the UAS.
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As set forth herein, UCay, Inc DBA Skyhawk Video & Photography 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 UAS 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 UCay, Inc DBA Skyhawk Video & 

Photography to safely, efficiently, and economically operate the DJI Inspire 1 UAS 

commercially within the NAS.

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

Modernization and Reform Act of 2012, Section 333, UCay, Inc DBA Skyhawk Video & 

Photography 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 Skyhawk Video 

& Photography to operate the DJI Inspire 1 UAS commercially for the purpose of conducting 

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

June 10, 2015 
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APPENDIX – A

DJI Inspire 1 Manufacturer’s User Manual

http://download.djiinnovations.com/downloads/inspire_1/en/Inspire_1_User_Manual_v1.0_en.pdf