Submitted by:

Kevin Maw

Totalorlando LLC

1420 Celebration Blvd. Suite 200 Celebration, FL 34747 

kev@totalorlando.com

Scope:

To produce real estate listing photography and videos by using 

the DJI Inspire 1 Professional Unmanned Aircraft. 

UAV DJI Inspire 1 Professional:

The DJI Inspire 1 is a quad-rotor Unmanned Aircraft System 

(UAS) weighing less than 7 pounds. 

The DJI Inspire 1 that Totalorlando LLC will be responsible for 

also utilizes a mobile ground station. 

The UAS features a safety Return to Home function that in the 

event of a signal loss, the UAS will return to a preset position and 

land. The Return to Home feature can also be triggered manually. 

The remote controller connects to a phone or tablet, offering 

additional live observational information at high quality 720p. 

Although safe operation of the DJI Inspire 1 will be the sole 

responsibility of the PIC, the advanced system does benefit from 

the following backup safety systems;

 Clearly visible design with directional indicators

 A low power/lost signal ‘Return To Home’ feature

 The DJI Inspire 1 system prevents navigation within 

restricted areas of A/B airfields

 The precision controller is aided by GPS for stability and 

location accuracy and allows the operator to combine line of 

sight, live feed camera observation, and the emergency 

‘return home’ system for a safe and controlled flight.
Request:

An exemption from 91.7(a), 91.119, 91.121, 91.151(a), 91.405(a), 

91.407(a)(1), 91.409(a)(2) and 91.417(a) and (b) of Title 14, Code 

of Federal Regulations (14 CFR) as was granted to Ralph J. Apel 

in Exemption No. 11410 

Petition:

I request an exemption from TITLE 14 OF THE CODE OF 

FEDERAL REGULATIONS SECTIONS 61.113 (a) and (b); 91.7 

(a); 91.119 (c); 91.121; 91.151 (a); 91.405 (a); 91.407 (a) (1); 

91.409 (a) (1) and (2); 91.417 (a) and (b) 

The Extent Of Relief that TotalOrlando LLC seeks

1. Extent of Relief that TotalOrlando LLC seeks regarding 

Section 61.113 (a) and (b) Private Pilot Privileges and 

Limitations 

Relief from Section 61.113 (a) and (b) is requested to allow a Pilot 

in Command holding a current Private Pilots Certificate to operate 

the TotalOrlando LLC DJI Inspire 1. The flight would be 

complimented by a Visual Observer who, along with the pilot, will 

maintain Visual Line of Sight with the DJI Inspire 1 at all times. 

All operations conducted will be incidental to Totalorlando LLC’s

business. The DJI Inspire is not able to carry passengers. 

2. Extent of Relief that TotalOrlando LLC seeks in regards to 

Section 91.7(a) 

Civil Aircraft Airworthiness Relief from Section 91.7(a) is 

requested to allow TotalOrlando LLC to determine airworthiness 

of the DJI Inspire 1. As part of this determination the following 

will be adhered to: 

a. Prior to the DJI Inspire 1's flight the PIC will inspect the UA to 
ensure it is in a condition that will be conducive for a safe flight. 

The ground control station will be included in the above 

inspection.

b. TotalOrlando LLC will follow the DJI Inspire 1’s 

aircraft/component, maintenance, overhaul, replacement, 

inspection and life limit requirements. 

c. TotalOrlando LLC will comply with all DJI manufacturer Safety 

Bulletins. 

3. Extent of Relief that TotalOrlando LLC seeks in regards to 

Section 91.119 

Minimum Safe Altitudes General relief from 91.119 is requested to 

allow TotalOrlando LLC to operate the DJI Inspire 1 at altitudes 

not to exceed 400’ AGL over private property at a distance at or 

greater than 5NM from the nearest airport as depicted on current 

Aeronautical Charts. TotalOrlando LLC also wishes to be granted 

exemption to operate at an altitude not greater than 50’ AGL 

(below tree level) between 1NM and 5NM from the nearest airport 

as depicted on current Aeronautical Charts. 

TotalOrlando LLC will adhere to the following in order to 

maintain an acceptable level of safety associated with operations 

over private property:(

a) TotalOrlando LLC will display signs in the immediate vicinity 

of operations stating: “Aerial Photography In Progress. Use 

Caution.” 

(b) TotalOrlando LLC will not allow the DJI Inspire 1 to operate at 

a speed greater than 10kts.

(c) TotalOrlando LLC will require the UAS operator (PIC) to be 

fully trained on the DJI Inspire 1 by adhering to the 

recommendations contained within the DJI Inspire 1’s operating 

manual. 
(d) TotalOrlando LLC will have accumulated and logged, in a 

manner consistent with 14 CFR 61.51, a minimum of 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. In addition the 

operator will have logged a minimum of 5 hours as a UAS pilot 

operating the make and model UAS that Flying TotalOrlando LLC

operates. 

(e) TotalOrlando LLC will be familiar with and able to manually 

institute the DJI Inspire 1’s Return to Home (RTH) feature. This 

feature aborts a flight operation and automatically returns the UAS 

to a predetermined GPS safe point. 

(f) TotalOrlando LLC will not operate over private property 

without first finding a suitable alternate landing spot on the 

property.

(g) TotalOrlando LLC will abort the flight in the event of 

unpredicted obstacles or emergencies in accordance with the 

operating documents. 

(h) TotalOrlando LLC will utilize a two man flight team consisting 

of the Pilot in Command (PIC) and a Visual Observer (VO). This 

team will maintain visual line of sight with the DJI Inspire 1 at all 

times and remain within hearing of one another. 

(i) TotalOrlando LLC will not permit flight around vessels, 

vehicles and structures without permission from the owner.

4. Extent of Relief that TotalOrlando LLC seeks in regards to 

Section 91.121 Altimeter Settings 

Relief from 91.121 is requested because the DJI Inspire 1 utilizes 

electronic GPS with a barometric sensor.In order to maintain an 

equal level of safety that 91.121 requires, the PIC of the 

TotalOrlando LLC’s UAS will abort the flight in the events that 

the UA loses communications with the GPS signal. 
5. Extent of Relief that TotalOrlando LLC seeks in regards to 

Section 91.151(b) Fuel Requirements for Flight in VFR 

conditions

Relief from 91.151(b) is requested to the extent that allows 

TotalOrlando LLC to operate the DJI Inspire 1 up to a point 

(considering wind and forecast weather conditions) that there is 

enough power to fly at normal cruising speed to the intended 

landing point and land the UA with 30% battery power remaining. 

6. Extent of Relief that TotalOrlando LLC seeks in regards to 

Sections 91.405(a), 91.407(a)(1), 91.409(a)(1), and (a)(2), 

91.417(a) and (b) 

These are all associated a with Airworthiness certificate 

Relief from 91.405(a), 91.407(a)(1), and (a)(2), And 91.417(a) and 

(b) is requested to the extent that allows TotalOrlando LLC to 

operate the DJI Inspire 1 Quad-Copter as necessary. These sections 

are all related to airworthiness certificates of aircraft. There is not 

currently an airworthiness certificate for small UAS’s. 

TotalOrlando LLC would comply in full to any conditions and 

limitations that the Administrator would place in order to receive 

an approved Grant of Exemption. 

Public Interest: 

Aerial videography for real estate marketing has been around for a 

long time through manned fixed wing aircraft and helicopters, but 

for small business owners, it's expense has been cost-prohibitive. 

Granting this exemption to me would allow me to provide this 

service at a much lower cost. TotalOrlando LLC’s UAS will pose 

no threat to the public given its small size and lack of combustible 

fuel when compared to manned aircraft. The operation of my UAS 

will minimize ecological damage and promote economic growth 

by providing additional occupancy of properties in the Kissimmee 

area of Central Florida. 
Conclusion:

As set forth herein, TotalOrlando LLC 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 

within the Real Estate markets. The Administrator will be assisting 

small business by granting this petition. In accordance with the 

FAA Modernization and Reform Act of 2012, TotalOrlando LLC 

respectfully requests that the FAA Administrator grants this 

petition for exemption from TITLE 14 OF THE CODE OF 

FEDERAL REGULATIONS SECTIONS 61.113 (a) and (b); 91.7 

(a); 91.119 (c); 91.121; 91.151 (a); 91.405 (a); 91.407 (a) (1); 

91.409 (a) (1) and (2); 91.417 (a) and (b)