UNITED STATES OF AMERICA

DEPARTMENT OF TRANSPORTATION

FEDERAL AVIATION ADMINISTRATION

WASHINGTON, DC

Regulatory Docket No. _______________

IN THE MATTER OF THE PETITION FOR EXEMPTION OF:

Mikon Haaksman dba Haaksman Media

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 UNMANNED AIRCRAFT

SYSTEMS

PURSUANT TO SECTION 333 OF

THE FAA MODERNIZATION AND REFORM ACT OF 2012 (PUBLIC LAW 112-95)

Submitted on August 19th, 2015

Mikon Haaksman 

3346 Pebble Beach Drive

Farmers Branch, TX 75234

940-784-3361

Page 1 of 33
TABLE OF CONTENTS

Page

GLOSSARY OF 

ABBREVIATIONS................................................................................3

SUMMARY..........................................................................................4

INTRODUCTION AND INTERESTS OF PETITIONER..................................4

BACKGROUND....................................................................................5

BASIS FOR PETITION..........................................................................5

NAME AND ADDRESS OF PETITIONER................................................6

THE SPECIFIC SECTIONS OF 14 C.F.R. FROM WHICH MIKON HAAKSMAN

SEEKS EXEMPTION..........................................................................7

THE EXTENT OF RELIEF Mikon Haaksman AND THE REASON MIKON HAAKSMAN 

SEEKS THE RELIEF........................................................................10

THE REASONS WHY GRANTING MIKON HAAKSMAN’S REQUEST WOULD

BE IN THE PUBLIC INTEREST ..........................................................12

THE REASONS WHY GRANTING THE EXEMPTION WOULD NOT

ADVERSELY AFFECT SAFETY...........................................................14

SUMMARY THAT CAN BE PUBLISHED IN THE FEDERAL REGISTER......25

ANY ADDITIONAL INFORMATION, VIEWS, OR ARGUMENTS

AVAILABLE TO SUPPORT MIKON HAAKSMAN’S

REQUEST.......................................................................................25

CONCLUSION...................................................................................26

APPENDICES........................................................................................26

Page 2 of 33
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

Page 3 of 33
SUMMARY

Mikon Haaksman 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 Mikon Haaksman to operate an Unmanned Aircraft System (UAS) for the 

commercial purpose of conducting aerial video and photography for corporate 

videography, real estate photography and videography, special events, documentaries, 

television production, and landscape over certain areas of the United States.

INTRODUCTION AND INTERESTS OF THE PETITIONER

Mikon Haaksman provides its clients with expertise and knowledge in advanced 

technologies and solutions to increase efficiency, productivity and effectiveness. The 

company also provides its clients with the highest quality digital content for use in their 

commercial, personal, and non-profit multimedia projects. Mikon Haaksman has over 20 

years of professional experience in corporate, broadcast, documentary, and narrative 

production and is recognized as an expert this field. Mikon Haaksman has over 2 years 

of recreational/hobby experience in all aspects of aerial video and photography, as well 

as 11 years experience in operating hobby aircraft. My objective is to provide safe

high quality imaging for a variety of corporate, commercial, public, and residential uses,

specifically targeting:

• Corporate Videography and Photography

• Special Event Filming

• Real Estate Photography and Videography

• Broadcast Television and Documentary Filming

• Increase public knowledge of UAS and promote safe UAS operations.

Page 4 of 33
BACKGROUND

Unmanned Aircraft Systems: DJI Inspire 1

Mikon Haaksman seeks an exemption to operate DJI systems for compensation or hire 

within the NAS. DJI Inspire 1 is a vertical takeoff and landing (VTOL) Unmanned Aircraft 

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

systems. DJI Inspire 1 has a maximum gross weight of

approximately 6.47057 pounds, while having a length of 17.24 inches width of 17.75 

inches, height of 11.85 inches, and a maximum speed of approximately 43 knots. The 

DJI Inspire 1 is equipped with four main rotors; driven by Lithium Polymer battery

powered electric motors. DJI Inspire 1 UAS that will be operated by Mikon Haaksman 

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, Mikon Haaksman dba Haaksman Media, 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 DJI Inspire 1 UAS

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, Mikon Haaksman dba Haaksman Media’s 

operation of DJI Inspire 1 UAS 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, Mikon Haaksman 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.

Mikon Haaksman submits that the requested relief is proper since an equivalent level of 

safety will be ensured. Mikon Haaksman will use experienced personnel or technicians 

to perform maintenance, alterations, or preventive maintenance on the UAS using the 

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

Monthly Maintenance Log, and DJI Inspire 1 Instruction Manual). Furthermore Mikon 

Haaksman will document and maintain all maintenance records for the DJI Inspire 1

UAS.

Page 5 of 33
Relief from certain requirements of Section 61.113(a) and (b), entitled Private pilot

privileges and limitations: Pilot in command, is requested by Mikon Haaksman to the 

extent necessary to allow a Pilot in Command (PIC) holding a private pilot or higher 

level certificate, as well as 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 UAS in a manner consistent with this exemption, including

evasive and emergency maneuvers and maintaining appropriate distances from people,

vessels, vehicles and structures.

Mikon Haaksman seeks relief from Section 91.7(a), entitled Civil aircraft airworthiness, 

because DJI Inspire 1 UAS does not require an airworthiness certificate in accordance 

with 14 C.F.R. Part 21, Subpart H. As such, Mikon Haaksman submits that he will 

ensure that DJI Inspire 1 UAS is in an airworthy condition, prior to every flight, by 

determining that the UAS is in compliance with the operating documents (i.e., Monthly 

Maintenance Log, and DJI Inspire 1Instruction Manual), and that the aircraft is in a 

condition for safe flight.

Mikon Haaksman also seeks an exemption from the requirements of Section 91.121,

entitled Altimeter Settings, as DJI Inspire 1 UAS will not have a typical

barometric altimeter onboard. However, altitude information of the DJI Inspire 1 UAS will 

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

communications telemetry data link, which downlinks from the UA to

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

Mikon Haaksman’s operation of DJI Inspire 1 UAS within visual line of

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

91.121.

Additionally, Mikon Haaksman seeks an exemption from the requirements of

Section 91.151(b), entitled Fuel requirements for flight in VFR conditions. Mikon 

Haaksman dba Haaksman Media submits that safety will not be affected by operation 

of DJI Inspire 1 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 14.5 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, Mikon Haaksman 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:

Mikon Haaksman dba Haaksman Media

3346 Pebble Beach Drive

Farmers Branch, Tx 75234

mikon@haaksmanmedia.com

940-784-3361

Page 6 of 33
B. The Specific Sections Of 14 C.F.R. From Which Mikon Haaksman Seeks 

Exemption.

1. Mikon Haaksman 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. Mikon Haaksman 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. Mikon Haaksman 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. Mikon Haaksman Seeks Exemption From The Requirements Of Section

91.151(b).

Page 7 of 33
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. Mikon Haaksman 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. Mikon Haaksman 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. Mikon Haaksman 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. Mikon Haaksman Seeks Exemption From The Requirements Of Sections

91.417(a) And 91.417(b).

Page 8 of 33
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:

Page 9 of 33
(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 Mikon Haaksman Seeks And The Reason Mikon Haaksman 

Seeks The Relief.

1. Extent Of Relief Mikon Haaksman Seeks And The Reason Mikon 

Haaksman dba Haaksman Media 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 

holding a private pilot or higher level certificate, as well as a current and valid airman 

medical certificate, and 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, Mikon Haaksman submits that an equivalent level of

safety will be maintained because no PIC will be allowed to operate the DJI Inspire 1 

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

demonstrating that the PIC is able to safely operate DJI Inspire 1 UAS 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, Mikon Haaksman submits that all flights of DJI Inspire 1 UAS, conducted by 

the PIC pursuant to the grant of this Petition: (1) will be incidental to

Mikon Haaksman’s business; and (2) will not carry passengers or property for 

compensation or hire.

2. Extent Of Relief Mikon Haaksman Seeks And The Reason Mikon Haaksman 

dba Haaksman Media 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 Mikon Haaksman to determine that DJI Inspire 1 

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

Page 10 of 33
compliance with the operating documents (i.e., Monthly Maintenance Log, and DJI

Inspire 1Instruction Manual).

Mikon Haaksman seeks the requested relief because DJI Inspire 1 UAS does not 

require an airworthiness certificate in accordance with 14 C.F.R. Part 21,

Subpart H. Therefore, Mikon Haaksman will ensure that DJI Inspire 1 UAS

is in airworthy condition based upon its compliance with the operating documents (i.e.,

Monthly Maintenance Log, and DJI Inspire 1 Instruction Manual) prior to

every flight, and further, determine that the aircraft is in condition for safe flight, as 

stated in the conditions and limitations below.

3. Extent Of Relief Mikon Haaksman Seeks And The Reason Mikon Haaksman 

dba Haaksman Media

Seeks Relief From Section 91.121.

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

flight operations of DJI Inspire 1 UAS, 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), Mikon Haaksman 

dba Haaksman Media seeks the requested relief because DJI Inspire 1 UAS 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 DJI Inspire 1 UAS is 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 Mikon Haaksman Seeks And The Reason Mikon Haaksman

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 UA during daylight hours in visual meteorological conditions

(VMC), under visual flight rules (VFR), for a total duration of 14.5 minutes to the first

point of intended landing and, assuming normal cruising speed, to fly after that for at 

least 4.5 minutes. Mikon Haaksman seeks the requested relief because without an 

exemption from Section 91.151(b), the flight time duration of the battery powered DJI 

Inspire 1 UAS will severely constrain the practicality of any aerial video or still photo

flight operations that Mikon Haaksman proposes to conduct pursuant to this Petition.

Significantly, as set forth below, the technical specifications of the DJI Inspire 1, DJI 

Inspire 1 operating documents, and Mikon Haaksman’s proposed operating limitations, 

Page 11 of 33
ensure that Mikon Haaksman will safely operate the battery powered DJI Inspire 1 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 Mikon Haaksman Seeks And The Reason Mikon Haaksman 

dba Haaksman Media 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, Mikon Haaksman requests relief 

from these Sections because DJI Inspire 1 UAS does not require airworthiness

certificates. As set forth more fully below, DJI Inspire 1 UAS meets the

conditions of FMRA Section 333 for operation without an airworthiness certificate.

Accordingly, Mikon Haaksman will use trained technicians to perform maintenance,

alterations, or preventive maintenance on the UAS using the methods, techniques, and

practices prescribed in the UAS operating documents (i.e., Monthly Maintenance Log, 

and DJI Inspire 1 ). Furthermore, Mikon Haaksman will document and maintain all

maintenance records for DJI Inspire 1 UAS.

D. The Reasons Why Granting Mikon Haaksman dba Haaksman Media’s 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 Mikon Haaksman

to safely, efficiently, and economically perform aerial video and photography for

corporate videography, real estate photography and videography, special events, 

documentaries, television production, and landscape over certain areas of the United 

States.

Additionally, use of DJI Inspire 1 UAS will decrease congestion

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

the benefits of Mikon Haaksman’s proposed operation of DJI Inspire 1 UAS

will be realized without implicating any privacy issues.

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

DJI Inspire 1 UAS is battery powered and serves 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 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. 

Page 12 of 33
The DJI Inspire 1 UAS does 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

UAS.

Conducting aerial acquisitions with DJI Inspire 1 UAS, 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, DJI Inspire 1 UAS produces 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. DJI Inspire 1 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 DJI Inspire 1 UAS to perform aerial acquisitions, the

substantial risk to life and property in the air and on the ground, which is usually 

associated with traditional access methods, will be substantially reduced or completely 

eliminated. Aside from the lack of flight crew members located onboard the aircraft, the 

DJI Inspire 1 UAS (weighing approximately 6.47057 pounds, at its maximum gross

weight with a length of 17.24 inches, widths of 17.75 inches, and with no fuel on board), 

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 UAS Will Benefit The Economy.

In addition to being safe and efficient, DJI Inspire 1 UAS is also

an economical alternative to using manned aircraft to conduct similar aerial operations. 

As such, operation of DJI Inspire 1 UAS will allow United States based

companies, like Mikon Haaksman, 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 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 DJI Inspire 1 UAS, companies such as Mikon Haaksman’s, 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.

Page 13 of 33
economy. Improved financial performance of U.S. companies, through commercial use 

of DJI Inspire 1 UAS, 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, Mikon Haaksman’s proposed operation of DJI Inspire 1 UAS will

not implicate any privacy issues. Specifically, DJI Inspire 1 UAS will be

operated only in compliance with operating documents (i.e., Monthly Maintenance Log,

and DJI Inspire 1 ) 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 Mikon Haaksman Seeks Exemption.

1. Reasons Why DJI Inspire 1 UAS Meets 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, Mikon Haaksman’s operation of the DJI

Inspire 1 UAS meets 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

Page 14 of 33
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, Mikon Haaksman submits that the DJI Inspire 1 UAS 

can operate safely in the NAS pursuant to FMRA Section 333, as demonstrated by: (a) 

the characteristics of DJI Inspire 1 UAS; (b) the pilot certification requirement; and (c) 

the specific operating limitations.

a. The Specifications Of DJI Inspire 1 UAS Demonstrate

Its Safe Characteristics.

The DJI Inspire 1 UAS does 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 DJI Inspire 1 UAS.

The technical specification of DJI Inspire 1 UAS is set forth by the DJI Inspire 1 

Specifications and Data Sheet, attached hereto as Exhibit A.

ii. DJI Inspire 1 UAS Autonomous Flight And

Navigation Modes Enable The UAS To Remain Within A Defined

Operational Area.

DJI Inspire 1 UAS may be operated in both manual and fully autonomous flight modes. 

A complete description of the flight and navigational modes of

DJI Inspire 1 UAS is provided at page 12 of the DJI Inspire 1 and page 60 User 

Manual, attached hereto as Exhibit B .

iii. DJI Inspire 1 UAS is 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, DJI Inspire 1 UAS will remain stationary, in flight, for 3 

seconds or more. If, after 3 seconds, the DJI Inspire 1 UAS does 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 DJI Inspire 1 

Page 15 of 33
UAS are set forth at pages 13 through 15 of DJI Inspire 1 User Manual, attached 

hereto as Exhibit B.

iv. DJI Inspire 1 GCS And Its Operation.

A complete description of the operation and specifications of the DJI Inspire 1 GCS and 

flight control software is provided at pages 40 through 43 of the DJI Inspire 1 User 

Manual. DJI Inspire 1 User Manual is attached hereto as Exhibits B.

b. Flight Operations Of DJI Inspire 1 UAS is Limited To The

Line Of Sight Of A Pilot in Command With A Safety Observer.

Mikon Haaksman will only utilize pilots who possess a current and valid medical 

certificate to act as a pilot in command (PIC) of DJI Inspire 1 UAS.

Additionally, a safety observer will assist all pilots during flight time.

c. Flights Of DJI Inspire 1 UAS Will Be Conducted Pursuant

To Specific Operating Limitations.

In seeking this exemption, Mikon Haaksman proposes to commercially operate DJI

Inspire 1 UAS 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 UAS

weighing less than 55 pounds maximum gross weight: DJI Inspire 1

Professional 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 43 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 UA must be operated within visual line of sight (VLOS) of the PIC at all

times. This requires the PIC to be able to use human vision unaided by any

device other than corrective lenses.

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

Page 16 of 33
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.

Page 17 of 33
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 UAS 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 possess at least a current medical certificate.

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 5 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 500 feet below or less than 2,000 feet

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

PIC.

Page 18 of 33
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 (N- Number) 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

Page 19 of 33
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.

Mikon Haaksman 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 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 UAS in a manner consistent with the exemption, including evasive

and emergency maneuvers and maintaining appropriate distances from people, 

vessels, vehicles and structures.

Considering Mikon Haaksman’s proposed area of operations, and the operating

limitations set forth-above; the parallel nature of private pilot aeronautical knowledge

requirements to those of commercial pilot requirements (See Exemption No. 11062); 

and the airmanship skills necessary to safely operate DJI Inspire 1 UAS,

Mikon Haaksman submits that the additional manned airmanship experience of a

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

Mikon Haaksman dba Haaksman Media’s specific proposed flight operations.

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

26 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).

Mikon Haaksman will not allow any PIC to operate DJI Inspire 1 

Page 20 of 33
UAS unless that PIC has demonstrated, by meeting minimum flight-hour requirements 

or DJI Inspire 1 UAS training and currency requirements, that the PIC is

able to safely operate DJI Inspire 1 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 Mikon Haaksman’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 multi-rotor 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, Mikon Haaksman will ensure safe operations by not allowing any PIC to

operate DJI Inspire 1 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 UAS in a manner consistent with the exemption, including evasive and 

emergency maneuvers and maintaining appropriate distances from people,

vessels, vehicles and structures.

Page 21 of 33
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, Mikon Haaksman will ensure that the DJI Inspire 1

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.

28

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 DJI Inspire 1 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 Mikon Haaksman’s operation of the DJI Inspire 

1 Professional 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 UAS 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 UAS; (2) the limitations on the proposed flight operations; and (3)

the location of the proposed flight operations. Accordingly, Mikon Haaksman will ensure 

that it will safely operate the battery powered DJI Inspire 1 UAS during daylight

hours in VFR conditions, with enough battery power to fly for a total duration of 14.5

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 UAS; 

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.

Page 22 of 33
Section 91.151(b). Furthermore, safety will be ensured as DJI Inspire 1 

UAS 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, DJI Inspire 1 UAS 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, Mikon Haaksman 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 Mikon Haaksman will use trained technicians to perform maintenance, 

alterations, or preventive maintenance on the UAS using the methods, techniques, and 

practices prescribed in the operating documents (i.e., Monthly Maintenance Log, and 

DJI Inspire 1 Instruction Manual). Furthermore, Mikon Haaksman will document and 

maintain all maintenance records for DJI Inspire 1 UAS.

Since DJI Inspire 1 UAS will be inspected as prescribed by the

operating documents, Mikon Haaksman 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 User Manual is attached hereto as Exhibit B; a copy of the DJI

Inspire 1 UAS Maintenance LOG is attached hereto as Exhibit C.

Likewise, the exemption sought will not adversely affect safety because Mikon 

Haaksman 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 UAS 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

Page 23 of 33
not adversely affected when the technical characteristics and operating limitations of the

UAS are considered.

In consideration of Mikon Haaksman dba Haaksman Media’s proposed operating 

limitations, the operating documents, and the technical aspects of DJI Inspire 1 UAS, 

Mikon Haaksman 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, Mikon Haaksman requests 

that the FAA prescribe special conditions for the intended operation of the DJI Inspire 1

UAS, 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 DJI Inspire 1 UAS, 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 Leading Edge’s intended operation of the DJI

Page 24 of 33
Inspire 1 UAS, 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 Mikon Haaksman Seeks Exemption:

Mikon Haaksman 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 Mikon Haaksman Seeks:

This exemption will permit Mikon Haaksman 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 Mikon 

Haaksman’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, Mikon Haaksman’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, Mikon Haaksman will operate the DJI Inspire 1 UAS 

safely in the NAS, without creating a hazard to users of the NAS, or the

public, or otherwise pose a threat to national security.

As set forth herein, Mikon Haaksman 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 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

Page 25 of 33
Reform Act of 2012, while also advancing the interests of the public, by allowing Mikon 

Haaksman to safely, efficiently, and economically operate 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, Mikon Haaksman 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 Mikon Haaksman to operate the 

DJI Inspire 1UAS commercially for the purpose of conducting aerial video and

photography over certain areas of the United States.

Dated: August 19th, 2015

Respectfully submitted,

Mikon Haaksman

_________________________

Mikon Haaksman 

3346 Pebble Beach Drive

Farmers Branch, TX 75234

Appendices:

A – DJI Inspire 1 Specifications Data Sheet 

B – DJI Inspire 1 Manufacturer’s User Manual

C – Monthly Maintenance Log

APPENDIX – A

DJI Inspire 1 TECHNICAL SPECIFICATIONS

Mikon Haaksman only utilizes safe and reliable UAS. DJI is an industry leader in small 

UAS production. DJI UAS 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 realtime altitude and location information to the PIC via the linked monitor (smart phone/

tablet devices)

1.1 DJI Inspire 1 

Model

Page 26 of 33
T600

Weight (Battery Included)

2935 g

Hovering Accuracy (Gps Mode)

Vertical: 0.5 m

Horizontal: 2.5 m

Max Angular Velocity

Pitch: 300°/s

Yaw: 150°/s

Max Tilt Angle

35°

Max Ascent Speed

5 m/s

Max Descent Speed

4 m/s

Max Speed

22 m/s (ATTI mode, no wind)

Max Flight Altitude

4500 m

Max Wind Speed Resistance

10 m/s

Max Flight Time

Approximately 18 minutes

Motor Model

DJI 3510

Propeller Model

DJI 1345

Indoor Hovering

Enabled by default

Operating Temperature Range

-10° to 40° C

Diagonal Distance

559 to 581 mm

Dimensions

438x451x301 mm

Gimbal 

Model

ZENMUSE X3

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Output Power (With Camera)

Static: 9 W

In Motion: 11 W

Operating Current

Station: 750 mA

Motion: 900 mA

Angular Vibration Range

±0.03°

Mounting

Detachable

Controllable Range

Pitch: -90° to +30°

Pan: ±320°

Mechanical Range

Pitch: -125° to +45°

Pan: ±330°

Max Controllable Speed

Pitch: 120°/s

Pan: 180°/s

Camera 

Name

X3

Model

FC350

Total Pixels

12.76M

Effective Pixels

12.4M

Image Max Size

4000x3000

Iso Range

100-3200 (video)

100-1600 (photo)

Electronic Shutter Speed

8s - 1/8000s

Fov (Field Of View)

94°

Cmos

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Sony EXMOR 1/2.3”

Lens

20mm (35mm format equivalent)f/2.8 focus at ∞

9 Elements in 9 groups

Anti-distortion

Still Photography Modes

Single shoot

Burst shooting: 3/5/7 frames

Auto Exposure Bracketing (AEB): 3/5 bracketed frames at 0.7EV Bias

Time-lapse

Video Recording Modes

UHD (4K): 4096x2160p24/25, 3840x2160p24/25/30

FHD: 1920x1080p24/25/30/48/50/60

HD: 1280x720p24/25/30/48/50/60

Max Bitrate Of Video Storage

60 Mbps

Supported File Formats

FAT32/exFAT

Photo: JPEG, DNG

Video: MP4/MOV (MPEG-4 AVC/H.264)

Supported Sd Card Types

Micro SD

Max capacity: 64 GB. Class 10 or UHS-1 rating required.

Operating Temperature Range

0° to 40° C

Remote Controller 

Name

C1

Operating Frequency

922.7~927.7 MHz (Japan Only)

5.725~5.825 GHz

2.400~2.483 GHz

Transmitting Distance (Outdoor And Unobstructed)

2 km

Eirp

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

Video Output Port

USB, mini-HDMI

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Power Supply

Built-in battery

Charging

DJI charger

Dual User Capability

Host-and-Slave connection

Mobile Device Holder

Tablet or Phone

Max Mobile Device Width

170mm

Output Power

9 W

Operating Temperature Range

-10° to 40° C

Storage Temperature Range

Less than 3 months: -20° to 45° C

More than 3 months: 22° to 28° C

Charging Temperature Range

0-40° C

Battery

6000 mAh LiPo 2S

Charger 

Model

A14-100P1A

Voltage

26.3 V

Rated Power

100 W

Battery (Standard) 

Name

Intelligent Flight Battery

Model

TB47

Capacity

4500 mAh

Voltage

22.2 V

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Battery Type

LiPo 6S High voltage battery

Energy

99.9 Wh

Net Weight

570 g

Operating Temperature Range

-10° to 40° C

Storage Temperature Range

Less than 3 months: -20° to 45° C

More than 3 months: 22° C to 28° C

Charging Temperature Range

0° to 40° C

Max Charging Power

180 W

Battery (Optional) 

Name

Intelligent Flight Battery

Model

TB48

Capacity

5700 mAh

Voltage

22.8 V

Battery Type

LiPo 6S

Energy

129.96 Wh

Net Weight

670 g

Operating Temperature Range

-10° to 40° C

Storage Temperature Range

Less than 3 months: -20 to 45° C

More than 3 months: 22° to 28° C

Charging Temperature Range

0° to 40° C

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Max Charging Power

180 W

Vision Positioning 

Velocity Range

Below 8 m/s (2 m above ground)

Altitude Range

5-500 cm

Operating Environment

Brightly lit (lux > 15) patterned surfaces

Operating Range

0-250 cm

DJI GO App 

Mobile Device System Requirements

iOS 8.0 or later, Android 4.1.2 or later

Supported Mobile Devices

* Compatible with iPhone 5s, iPhone 6, iPhone 6 Plus, iPad Air, iPad Air Wi-Fi + 

Cellular, iPad mini 2, iPad mini 2 Wi-Fi + Cellular, iPad Air 2, iPad Air 2 Wi-Fi + 

Cellular, iPad mini 3, and iPad mini 3 Wi-Fi + Cellular. This app is optimized for 

iPhone 5s, iPhone 6, and iPhone 6 Plus.

* Compatible with Samsung tabs 705c, Samsung S6, Samsung S5, Samsung NOTE4, 

Samsung NOTE3, Google Nexus 9, Google Nexus 7 II, Ascend Mate7, Nubia Z7 mini, 

SONY Z3 EXPERIA, MI 3, MI PAD

*Support for additional Android devices available as testing and development continues.

APPENDIX – B

B – DJI Inspire 1 Manufacturer’s User Manual

http://download.dji-innovations.com/downloads/inspire_1/en/

Inspire_1_User_Manual_v1.0_en.pdf

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APPENDIX – C

C – Monthly Maintenance Log

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