1 

January 23, 2016 

Attn: 

U. S. Department of Transportation Docket Operations 

West Building Ground Floor, Room w12-140 

1200 New Jersey Ave, SE Washington, DC 20590 

UNITED STATES OF AMERICA 

DEPARTMENT OF TRANSPORTATION 

FEDERAL AVIATION ADMINISTRATION 

WASHINGTON, DC 

IN THE MATTER OF THE PETITION FOR EXEMPTION OF: 

PANORAMA AERIAL IMAGING, LLC 

RE: PANORAMA AERIAL IMAGING, LLC REQUESTS AN EXEMPTION FROM 

SECTIONS OF THE REQUIREMENTS OF TITLE 14 OF THE CODE OF FEDERAL 

REGULATIONS: PART 21, §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 A DJI INSPIRE 1 UNMANNED AIRCRAFT SYSTEM PURSUANT TO 

SECTION 33 OF THE FAA MODERNIZATION AND REFORM ACT OF 2012 (PUBLIC 

LAW 112-95)

Panorama Aerial Imaging, LLC 

PO Box 1917 

Naples, FL 34106 

Lance Maclean 

President
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TABLE OF CONTENTS

Page 

TABLE OF CONTENTS ................................................................................................................ 2 

GLOSSARY OF ABBREVIATIONS ............................................................................................ 3 

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

BACKGROUND ............................................................................................................................ 4 

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

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

THE SPECIFIC SECTIONS OF 14 C.F.R. FROM WHICH PETITIONER SEEKS 

EXEMPTION ................................................................................................................................. 7 

EXTENT OF RELIEF PETITIONER SEEKS AND THE REASON PETITIONER SEEKS 

RELIEF ...................................................................................................................................................... 10

REASONS WHY GRANTING PETITIONERS REQUEST WOULD BE IN THE PUBLIC 

INTEREST .................................................................................................................................... 12 

REASONS WHY GRANTING THE EXEMPTION WOULD NOT ADVERSELY AFFECT 

SAFETY ....................................................................................................................................... 13 

CONCLUSION ............................................................................................................................. 23 

Appendices:................................................................................................................................... 24 

 
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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) 

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 

 
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Panorama Aerial Imaging, LLC (hereinafter referred to as PETITIONER), 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 PETITIONER to operate an Unmanned Aircraft System (UAS) in 

the NAS for the commercial purpose of conducting aerial videography and photography of 

construction sites, residential and commercial real estate, civil landscapes and events over certain 

areas of the United States. 

INTRODUCTION AND INTERESTS OF THE PETITIONER

The objective of PETITIONER and its UAS aerial operations is to provide a more affordable, 

more flexible, high-quality production system for a variety of governmental, commercial, public, 

and residential uses, specifically targeting:

• Construction site evolution

• Real estate damage appraisals

• Real estate marketing

• Economic development 

• Broadcast antenna maintenance

• Special event coverage

• Tourism marketing 

BACKGROUND

PETITIONER seeks an exemption to operate an Inspire 1 UAS (Model T 600), manufactured by 

DJI, for compensation or hire within the NAS. The DJI Inspire 1 is a vertical takeoff and landing 

(VTOL) Unmanned Aircraft (UA) with a mobile Ground Control Station (GCS) which is similar 

to those used by model aircraft hobbyists. This is a commercially available “quad-copter” that 

provides the maneuverability, stability, and video/photo quality necessary for the intended 

business activity. This UAS has an integrated, gimbal-mounted, on-board camera capable of 

capturing high-resolution still photographs and video. It also has the capability of transmitting 

real time video to its GCS. 

Unmanned Aircraft System 

Basic Specifications 

 Dimensions: 17 3⁄4 in x 17 1⁄4 in. 11 3⁄4 in. 

 MTOW: 6.5 lbs. 

 Propulsion: Four DC electric motors driven by lithium-polymer batteries 

 Maximum forward velocity: 42kts 

 Maximum flying altitude of 400' AGL (visually limited) 

 Maximum duration: approximately ~18 min with 15% battery reserve 

 Operating frequencies: 5.628GHz-5.85 GHz for UAS control and 2.412MHz-2.462MHz 

for the video transmission/range extender (compliant with FCC regulations) 
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The DJI Inspire I provides several functions that help ensure safe flight. If allowed to obtain a 

GPS position prior to flight, the UAS will return to this position and automatically land should it 

lose a radio link with the ground station. In addition, should the battery level reach a critically 

low level the UAS will begin a slow and controlled decent and automatically land. Lastly, there 

is a built-in database of airports, and should the UAS approach an airport, it will automatically 

descend as it gets close and automatically land at a predetermined radius. More information on 

these safety functions can be found in the attached DJI Inspire 1 User Manual (pages 13-15 and 

pages 45-48). 

The DJI Inspire 1 that will be operated by PETITIONER will be registered and marked in 

accordance with 14 CFR Part 47, Identification and Registration Marking.

UAS Designated Operator 

The sole operator of the UAS under this petition is a FAA multi-engine airplane ATP-rated pilot 

holding a second class medical certificate with more than 6,000 hours of total flight time. 

Additionally, the operator has a Bachelor of Science degree in Aeronautical Engineering and a 

FAA mechanic certificate (airframe and powerplant ratings) and more than 30 years of 

experience safely flying and building amateur-built experimental aircraft and radio controlled 

fix-wing and multi-rotor model aircraft. Given this experience and training, the PETITIONER is 

well qualified to operate the UAS safely in support of its business activities. 

BASIS FOR PETITION

PETITIONER, pursuant to the provisions of the Federal Aviation Regulations (14 C.F.R. 

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

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

commercially operate the DJI Inspire 1, 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, PETITIONER’s operation of the 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, PETITIONER 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. 

PETITIONER submits that the requested relief is proper since an equivalent level of safety will 

be ensured. PETITIONER will use experienced personnel or qualified technicians to perform 

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

and practices prescribed in the operating documents (DJI Inspire 1 Maintenance Manual). 

Furthermore, PETITIONER will maintain records for all maintenance performed on the DJI 

Inspire 1 UAS. 
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Relief from certain requirements of Section 61.113(a) and (b), entitled Private pilot privileges 

and limitations: Pilot in command, is requested by PETITIONER 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 experience 

and currency requirements, that the PIC is able to safely operate the DJI Phantom UAS in a 

manner consistent with this exemption, including evasive and emergency maneuvers and 

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

PETITIONER seeks relief from Section 91.7(a), entitled Civil aircraft airworthiness, because the 

DJI Inspire 1 UAS does not require an airworthiness certificate in accordance with 14 C.F.R. 

Part 21, Subpart H. As such, PETITIONER submits that it will ensure that the DJI Inspire 1 UAS 

is in a condition for safe flight prior to each flight by determining that the UAS is in compliance 

with its operating documents (i.e. DJI Inspire 1 User Manual and Maintenance Manual). 

PETITIONER also seeks an exemption from the requirements of Section 91.121, entitled 

Altimeter Settings, as the DJI Inspire 1 UAS will not have a typical barometric altimeter 

installed. 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 PETITIONER’s operation of the 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, PETITIONER seeks an exemption from the requirements of Section 91.151(b), 

entitled Fuel requirements for flight in VFR conditions. PETITIONER submits that safety will 

not be affected by operation of the 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 18 minutes. Battery power indicators are also able to 

show the operator exactly how much battery power remains as well as how much time is needed 

to return safely back to the point of takeoff.

In accordance with 14 C.F.R. § 11.81, PETITIONER 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:

Panorama Aerial Imaging, LLC 

PO Box 1917 

Naples, FL 34106 

(239) 777-833 

Lance Maclean 

President 

lance.maclean@panorama-aerial.com 
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B. The specific sections of 14 C.F.R. from which PETITIONER 

seeks exemption 

1. PETITIONER 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. PETITIONER 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. PETITIONER 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. 
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4. PETITIONER seeks exemption from the requirements of section 91.151(b)

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

states the following: 

(b) No person may begin a flight in a rotorcraft under VFR conditions unless 

(considering wind and forecast weather conditions) there is enough fuel to fly to the first 

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

least 20 minutes. 

5. PETITIONER 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. PETITIONER 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. PETITIONER 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. 
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8. PETITIONER seeks exemption from the requirements of sections 91.417(a) and 

91.417(b)

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

following: 

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

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

(b) of this section: 

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

records of the 100-hour, annual, progressive, and other required or approved 

inspections, as appropriate, for each aircraft (including the airframe) and each 

engine, propeller, rotor, and appliance of an aircraft. The records must include-- 

(i) A description (or reference to data acceptable to the Administrator) of the 

work performed; and 

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

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

for return to service. 

(2) Records containing the following information: 

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

each rotor. 

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

rotor, and appliance. 

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

required to be overhauled on a specified time basis. 

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

last inspection required by the inspection program under which the aircraft 

and its appliances are maintained. 

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

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

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

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

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

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

and appliances. 

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

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

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

work is performed. 
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(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. Extent of relief PETITIONER seeks and the reason 

PETITIONER seeks the relief 

1. Extent of relief PETITIONER seeks and the reason PETITIONER 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-time 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, PETITIONER 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-time and currency requirements, demonstrating that the PIC is able to safely 

operate either the 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, PETITIONER submits that all flights of the DJI Inspire 1 UAS, conducted by the PIC 

pursuant to the grant of this Petition, (1) will be incidental to PETITIONER’s business; and (2) 

will not carry passengers or property for compensation or hire. 

2. Extent of relief PETITIONER seeks and the reason PETITIONER 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 PETITIONER to determine that the DJI Inspire 1 UAS is in airworthy 

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

documents (i.e. DJI Inspire 1 User Manual and Maintenance Manual). 

PETITIONER seeks the requested relief because the DJI Inspire 1 UAS does not require an 

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

PETITIONER will ensure that the DJI Inspire 1 UAS is in an “airworthy” condition based upon 
11 

its compliance with the operating documents (i.e. DJI Inspire 1 User Manual and Maintenance 

Manual) prior to every flight, and further, determine that the aircraft is in a condition for safe 

flight as stated in the conditions and limitations below.

3. Extent of relief PETITIONER seeks and the reason PETITIONER seeks relief from 

section 91.121

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

operations of the 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 (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), PETITIONER seeks the requested relief because the DJI Inspire 1 UA’s altimeter may 

be set on the ground to zero feet AGL, rather than the local barometric pressure or field altitude, 

before each flight. 

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

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

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

1 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 display of the GCS. 

4. Extent of relief PETITIONER seeks and the reason PETITIONER 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 UAS during 

daylight hours in visual meteorological conditions (VMC), under visual flight rules (VFR), for 

an approximate total duration of 18 minutes. PETITIONER 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 PETITIONER proposes to conduct pursuant to this Petition. 

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

Inspire 1 operating documents, and PETITIONER’s proposed operating limitations, ensure that 

PETITIONER 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 approximately 18 minutes.

5. Extent of relief PETITIONER seeks and the reason PETITIONER 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, PETITIONER requests relief from these Sections 
12 

because the DJI Inspire 1 UAS does not require an airworthiness certificate. As set forth more 

fully below, the DJI Inspire 1 UAS meets the conditions of FMRA Section 333 for operation 

without an airworthiness certificate. Accordingly, PETITIONER will use experienced and 

qualified 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. 

Panorama Aerial Imaging Operations Manual and DJI Inspire 1 Maintenance Manual). 

Furthermore, PETITIONER will record and maintain all maintenance actions performed on the 

DJI Inspire 1 UAS. 

D. Reasons why granting PETITIONER’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 PETITIONER to safely, 

efficiently, and economically perform low altitude aerial video and photography of construction 

sites, real estate, broadcast antennas, civic events and landscape over certain areas of the United 

States in a manner that is otherwise impractical, more expensive, more hazardous and less 

effective when performed by other means (e.g. manned helicopters, cranes, etc.). Notably, the 

benefits of PETITIONER’s proposed operation of the DJI Inspire 1 UAS will be implemented 

while giving due consideration to privacy issues.

1. The public will benefit from decreased congestion of the NAS

The DJI Inspire 1 UAS does not require an airport to takeoff or land thereby reducing the 

numbers of manned aircraft operating within the NAS. 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. This is especially applicable to some of the nation’s busiest general 

aviation airports.

2. The public will benefit from the safety and efficiency of the DJI Inspire 1 UAS

Conducting aerial acquisitions with the DJI Inspire 1 UAS, with its battery-powered electric 

propulsion system, will benefit the public by reducing the air and noise pollution that would 

otherwise be generated with internal combustion-powered manned aircraft. An aircraft’s noise 

footprint is especially significant during the noise-sensitive early morning hours when 

videography and photography is often performed. 

Aside from the lack of flight crew members located onboard the aircraft, the DJI Inspire 1 UAS 

(weighing approximately 6.5 lbs. at maximum gross weight with approximate diagonal 

dimension of 22 in., and with no combustible 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 and generally weigh thousands of pounds and 

hold highly flammable fuel. 
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Furthermore, the inspection of broadcast antennas, which is typically performed by humans 

ascending tall towers, can be performed by the DJI Inspire 1 UAS without creating undue risk to 

inspecting personnel. A permanent image record for future reference is an additional benefit. 

National Association of Tower Erectors recently published the following: “The commercial 

availability and deployment of UAS has the potential to complement and enhance the safety and 

well-being of communication tower workers who climb towers. UAS use will in some instances 

minimize the risks associated with climber fatigue, weather, and distractions, while reducing 

repetitive stress injuries. At the same time, UASs have and will continue to become an asset in 

multiple facets of the telecommunications industry, with the added benefits of cutting costs and 

promoting efficiency while assisting with tower inspections and site surveys. As a result, UAS 

deployment will enhance our nation’s vital communications capabilities.” 

3. Performing aerial video and photography operations with the DJI Inspire 1 UAS will 

benefit the economy

UAS such as the DJI Inspire 1 allow small businesses, such as the PETITIONER’s, opportunities 

to offer the public low-altitude, close-up aerial videography and photography services that have 

been heretofore been impossible or economically impractical using conventional manned 

aircraft. As a new business, the PETITIONER will be contributing to the overall growth of the 

local and national economies by hiring employees, purchasing new equipment and paying taxes. 

Given the limitations of the DJI Inspire 1 and small UASs in general (e.g. 400’ AGL and LOS), 

the economic impact to existing operators of conventional manned aerial videography and 

photography aircraft should be minimal. Manned aircraft typically have significant altitude, 

speed and payload capabilities that permit them to acquire other types of aerial imagery that is 

better suited for those aircraft. 

4. There are no privacy issues

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

PETITIONER’s proposed operation of the DJI Inspire 1 UAS will not implicate any privacy 

issues. Specifically, the DJI Inspire 1 UAS will be operated only in compliance with operating 

documents (Panorama Aerial Imaging Operations Manual) which requires property owner 

involvement, local law enforcement notification, and in some cases, ATC notification.

E. 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 PETITIONER seeks 

exemption 

1. Reasons why the 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, PETITIONER’s operation of the DJI Inspire 1 UAS meets 
14 

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

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

Section 333 provides authority for a UAS to operate without airworthiness certification and sets 

forth requirements for considering whether a UAS will create a hazard to users of the NAS or the 

public, or otherwise pose a threat to national security. Specifically, FMRA Section 333 states the 

following, in part: 

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

than 180 days after the date of enactment of this Act, the Secretary of Transportation 

shall determine if certain unmanned aircraft systems may operate safely in the national 

airspace system before completion of the plan and rulemaking required by section 332 of 

this Act or the guidance required by section 334 of this Act. 

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

subsection (a), the Secretary shall determine, at a minimum-- 

(1) which types of unmanned aircraft systems, if any, as a result of their size, 

weight, speed, operational capability, proximity to airports and populated areas, 

and operation within visual line of sight do not create a hazard to users of the 

national airspace system or the public or pose a threat to national security; and 

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

certification under section 44704 of title 49, United States Code, is required for 

the operation of unmanned aircraft systems identified under paragraph (1). 

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

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

the Secretary shall establish requirements for the safe operation of such aircraft systems 

in the national airspace system. 

In seeking this exemption, PETITIONER 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 the DJI 

Inspire 1 UAS; (b) the pilot certification requirement; and (c) the specific operating limitations. 

a. The specifications of the 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. 

b. Technical specifications of the DJI inspire 1 UAS

The technical specifications of the DJI Inspire 1 UAS are set forth by the DJI Inspire 1 User 

Manual, attached hereto as Appendix A. 

c The DJI inspire 1 UAS global positioning modes enable the UAS to remain within a 

defined operational area

The DJI Inspire 1 UAS may be operated in both manual and global positioning flight modes. A 

complete description of the flight and navigational modes of the DJI Inspire 1 UAS is provided 

at pages 12 of the DJI Inspire 1 User Manual attached hereto as Appendix A. 
15 

d. The 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, the 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 will return to the home 

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

A complete description of the Failsafe Functions of the DJI Inspire 1 UAS are set forth at pages 

13 of the DJI Inspire 1 User Manual, attached hereto as Appendix A. 

e. The 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 in pages 24 through 34 of the DJI Inspire 1 User Manual, attached 

hereto as Appendix A. 

f. Flight operations of DJI inspire 1 UAS is limited to the line-of-sight of a certificated pilotin-command with a safety observer

PETITIONER’s designated operator will be the only person to act as pilot in command (PIC) of 

the DJI Inspire 1 UAS as per the PETITIONER’s Operations Manual. Additionally, a safety 

observer will assist the PIC at all times during flight. 

g. Flights of DJI inspire 1 UAS will be conducted pursuant to specific operating limitations

In seeking this exemption, PETITIONER 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 

lbs. maximum gross weight: DJI Inspire 1 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 UA may not be flown at an indicated airspeed exceeding 20 knots.

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

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

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

in feet AGL. 

5. The 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, as specified on the PIC’s FAA-issued airman medical certificate. 

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

permitted. 
16 

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

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

and PIC must be able to communicate verbally at all times. Electronic messaging or 

texting is not permitted during flight operations. The PIC must be designated before 

the flight and cannot transfer his or her designation for the duration of the flight. The 

PIC must ensure that the SO can perform the functions prescribed in the operating 

documents. 

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

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

permitted to operate the camera or other instruments. 

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

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

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

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

limitations contained in the grant of exemption take precedence and must be followed. 

Otherwise, the operator must follow the procedures as outlined in its operating 

documents. The operator may update or revise its operating documents. It is the 

operator’s responsibility to track such revisions and present updated and revised 

documents to the Administrator upon request. The operator must also present updated 

and revised documents if it petitions for extension or amendment to the grant of 

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

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

amendment to its grant of exemption. The FAA’s UAS Integration Office (AFS-80) 

may be contacted if questions arise regarding updates or revisions to the operating 

documents. 

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

for safe flight. If the inspection reveals a condition that affects the safe operation of the 

UAS, the aircraft is prohibited from operating until the necessary maintenance has 

been performed and the UAS is found to be in a condition for safe flight. The Ground 

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

alterations must be properly documented in the aircraft records. 

 11. Any UAS that has undergone maintenance or alterations that affect the UAS 

operation or flight characteristics, e.g. replacement of a flight critical component, must 

undergo a functional test flight. The PIC who conducts the functional test flight must 

make an entry in the aircraft records. 

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

inoperable components, items, or equipment, not already covered in the relevant 

sections of the operating documents. 

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

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

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

requirements, in accordance with the operating documents. Maintenance, inspection, 
17 

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 private pilot certificate and at least a current thirdclass 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. 

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. 
18 

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

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

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

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

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

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

transponder requirements. 

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

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

as large as practicable. 

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

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

or other appropriate government oversight agency requirements. 

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

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

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

official upon request. 

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

operations and activities at all times. 

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

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

persons (persons other than the PIC, SO, operator trainees or essential persons), 

vessels, vehicles, and structures unless: 

a. Barriers or structures are present that sufficiently protect nonparticipating persons 

from the UA and/or debris in the event of an accident. The operator must ensure that 

nonparticipating persons remain under such protection. If a situation arises where 

nonparticipating persons leave such protection and are within 500 feet of the UA, 

flight operations must cease immediately and/or; 

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

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

PIC has made a safety assessment of the risk of operating closer to those objects and 

determined that it does not present an undue hazard, and; 

c. Operations nearer to the PIC, SO, operator trainees or essential persons do not 

present an undue hazard to those persons per § 91.119(a). 

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

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

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

to be conducted. 
19 

 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

PETITIONER 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 time 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 PETITIONER’s proposed area of operations, and the operating limitations set forthabove; 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 the DJI Inspire 1 UAS, PETITIONER submits that the additional manned 

airmanship experience of a commercially certificated pilot would not correlate to the airmanship 

skills necessary for PETITIONER’s specific proposed flight operations. 

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

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

11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112, 11136, 11138, 11150, 

11153, 11156, 11158, 11159, 11160, 11161). 

PETITIONER will not allow any PIC to operate the DJI Inspire 1 UAS unless that PIC has 

demonstrated, by meeting minimum flight-hour requirements or the DJI Inspire 1 UAS training 

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. 

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 PETITIONER’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 
20 

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 experiencebuilding 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, PETITIONER will ensure safe operations by not allowing any PIC 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. 

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, PETITIONER 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. Exemption Nos. 

11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112, 11136, 11138, 11150, 

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

4. Reasons why an exemption from the requirements of section 91.121 would not adversely 

affect safety

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

altitude information of the DJI Inspire 1 UAS will be provided to the PIC via GPS equipment 
21 

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 

PETITIONER’s operation of the 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. 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, PETITIONER will ensure that it will safely operate the batterypowered DJI Inspire 1 UAS during daylight hours in VFR conditions, with enough battery power 

to fly for a total duration of approximately 18 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. Section 91.151(b). Furthermore, 

safety will be ensured as the 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, the 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, PETITIONER 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 PETITIONER will 
22 

use qualified technicians to perform maintenance, alterations, or preventive maintenance on the 

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

DJI Inspire 1 User Manual and Maintenance Manual). Furthermore, PETITIONER will record 

and maintain all maintenance performed on the DJI Inspire 1 UAS. 

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

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

affected when the technical characteristics and operating limitations of the UAS are considered. 

In consideration of PETITIONER’s proposed operating limitations, the operating documents, 

and the technical aspects of the DJI Inspire 1 UAS, PETITIONER 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, PETITIONER 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 the 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 PETITIONER’s intended operation of the DJI 

Inspire 1 UAS, which contain such safety standards that the Administrator finds necessary to 
23 

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).

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, PETITIONER’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, PETITIONER 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. 

CONCLUSION

As set forth herein, PETITIONER 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 PETITIONER 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, PETITIONER 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 PETITIONER to operate the DJI Inspire 1 UAS 

commercially for the purpose of conducting aerial video and photography over certain areas of 

the United States. 

Respectfully submitted,

Panorama Aerial Imaging, LLC 

PO Box 1917 

Naples, FL 34106 

Lance Maclean 

President 

(239) 777-8331 

lance.maclean@panorama-aerial.com 
24 

Appendices:

A – Link to DJI Inspire 1 User Manual: 

https://dl.djicdn.com/downloads/inspire_1/en/Inspire_1_User_Manual_en_v2.0_1218.pdf DJI Inspire 1 

UAS Maintenance Log

B – Inspire 1 Maintenance Log 
Appendix – B 

Monthly Maintenance Log 

Monthly Maintenance Log 

UAS: Month: Year: 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 Maintenance Performed 

by: 

Date Issue 

Discovered 

Date Issue 

Addressed 

Issue Description & 

Maintenance 

Conducted Print Name Signature 

Software Updates 

Airframe 

Engines 

Propellers 

Camera Gimbal 

Landing Gear 

Vibration Dampening 

Other: