October	20,	2015	

U.	S.	Department	of	Transportation	Docket	Management	System	

1200	New	Jersey	Ave.,	

SE	Washington,	DC	20590

RE:	 Petition	of	Gani	Piñero	Photography,	LLC	for	Exemption	Pursuant	to	Section	333	of	the	

FAA	Reform	Act	

Petitioner: Gani	Piñero	Photography,	LLC	

Owner:	 Isagani	Piñero	

5744	Grisborne	Ave.,	Oakland,	CA	94611

gani@ganipinerophotography.com

To	whom	it	may	concern:	

Pursuant	to	Section	333	of	the	FAA	Modernization	and	Reform	Act	of	2012	(the	Reform	Act)	and	14	C.F.R.	

Part	11,	Gani	Piñero	Photography,	LLC,	an	operator	of	the	DJI	Inspire	1,	Small	Unmanned	Aircraft	System

(“SUAS”)	equipped	to	conduct	aerial	photography	and	videography,	hereby	applies	for	an	exemption	from	

the	listed	Federal	Aviation	Regulations	(“FARs”)	to	allow	commercial	operation	of	its	SUAS,	so	long	as	such	

operations	are	conducted	within	and	under	the	conditions	outlined	herein	or	as	may	be	established	by	

the	FAA	as	required	by	Section	333.1	As	described	more	fully	below,	the	requested	exemption	would	

permit	the	operation	of	small,	unmanned	and	relatively	inexpensive	SUAS under	controlled	conditions	in	

airspace	that	is	1)	limited	2)	predetermined	and	3)	controlled.	The	proposed	exemption,	if	granted,	would	

allow	Gani	Piñero	Photography,	LLC	to	conduct	commercial operations	of	SUAS meeting	or	exceeding	all	

of	the	operational	and	safety	requirements	Congress	has	set	forth	in	Section	333.	

Gani	Piñero	Photography,	LLC	is	a	photo/video	company	owned	and	operated	by	Isagani	Piñero.		Gani	

Piñero	Photography,	LLC	plans to	use	the	capabilities	of	SUAS to	offer	a	multitude	of	services,	including:

- Event	Photography/Videography

- Real	Estate	Photography	and	presentation

- Aerial	filmmaking	and	photography	

Statutory	Authority	Section	333,	titled	“Special	Rules	for	Certain	Unmanned	Aircraft	Systems”,	provides	a	

mechanism	for	seeking	expedited	FAA	authorization	of	safe	civil	Unmanned	Aircraft	Systems	(SUAS)	

operations	in	the	National	Airspace	System	(“NAS”).	Section	333(a)	states	that	the	FAA	“shall	determine	if	

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

of	the	(comprehensive)	plan	and	rule	making	required	by	section	332(b)(1)	of	this	Act	or	the	guidance	

required	by	section	334	of	this	Act.”	In	Section	332(b)(1),	Congress	made	it	clear	that	Section	333	provides	

a	mechanism	for	“expedited	operation	authorization”	if	several	factors	are	met.	Petitioner	meets	all	

requirements	to	permit	FAA	approval	of	commercial	SUAS operations.	

The	name	and	address	of	the	applicant are:	

Name:	Gani	Piñero	Photography,	LLC	

Owner:	Isagani	Piñero

Address:	5744	Grisborne	Ave.	Oakland,	CA	94611

Phone:	510-504-4258

Email:	gani@ganipinerophotography.com

Regulations	from	which	the	exemption	is	requested:	

14	C.F.R.	Part	21	

14	C.F.R.	45.23	(b)	

14	C.F.R.	61.113(a)	and	(b)	

14	C.F.R.	91.7	(a)	

14	C.F.R.	91.9	(b)(2)	
14	C.F.R.	91.109	

14	C.F.R.	91.119	

14	C.F.R.	91.121 Page	3	

14	C.F.R.	91.151(a)	

14	C.F.R.	91.203	(a)	&	(b)	

14	C.F.R.	91.205	(b)	

14	C.F.R.	91.215	14	C.F.R.	(91.401	- 91.417)	

SUAS are	oftentimes	seen	as	superior	to	helicopters	due	to	the	lesser	cost	of	equipment,	the	reduction	of	

personnel	needed	to	operate	equipment,	reduced	noise	levels	and	zero	emissions	into	the	environment.	

In	addition	to	providing	cost	savings	and	having	little	to	no	impact	on	the	environment,	SUAS provide	

enhanced	safety.	These	factors	are	beneficial	for,	and	in	the	best	interest	of,	the	public.	Accordingly,	the	

applicant	respectfully	requests	that	the	FAA	grant	the	requested	exemption	without	delay. Petitioner	is	

requesting	an	exemption	to	enable	Gani	Piñero	Photography,	LLC to	operate	a	DJI	Inspire	1	SUAS that	is	

upgraded	to	latest	version	firmware,	equipped	with	a	3	axis	Zenmuse	camera	gimbal,	which	uses	a	HighDefinition video	camera	that	can	capture	up	to	4K	(4096x2160p)	video	and	12M	pixel	photos.	This	SUAS

has	a	built-in	capability	to	limit	1)	the	height	it	flies	above	the	ground	and	2)	the	radius	of	the	distance	it	

flies	from	the	operator.	The	DJI	Inspire	1	also	has	the	failsafe	function	of	the autopilot	system,	which	

means,	when	the	communication	between	the	Main	Controller	and	the	transmitter	is	disconnected,	the	

outputs	of	all	command	sticks	from	controller	will	go	to	the	center	position.	If	the	GPS	signal	is	good	

enough,	the	system	will	automatically	trigger	Return	to	Home	and	will	land	safely.	Please	refer	to	

Attachments	1-3,	the	DJI	Inspire	1	Instruction	Manual,	for	the	performance	limitations	and	flight	

operations.	

Aircraft	weight	is	2935	grams	or	6.47	pounds	with	battery,	which	is	the	total	gross	weight.	A	pre-flight	

inspection	will	be	performed	by	the	PIC	in	accordance	with	the	factory	instruction	manual,	as	well	as	

redundant	checks	to	include	the	Internal	Measurement	Unit	(IMU)	to	make	sure	that	the	compass,	gyro	

and	acceleration	values are	within	specs,	positive	GPS	locks	are	secure,	battery	health	in	each	individual	

LiPo	cells	are	balanced,	and	radio	signals	are	locked	in.	The	SUAS will	be	maintained	in	accordance	with	

the	manufacturer’s	instruction	manual	and	only	manufacturer's	authorized	replacement	parts	will	be	

used.	FCC	Information.		

The	DJI	Inspire	1	transmitter	used	for	controlling	the	SUAS complies	with	part	15	of	the	FCC	rules.	

Operation	is	subject	to	the	following	two	conditions:	(1)	This	device	may	not	cause	harmful	interference,	

and	(2)	this	device	must	accept	any	interference	received,	including	interference	that	may	cause	

undesired	operation.	

The	DJI	Inspire1	radio	transmitter	used	for	controlling	the	SUAS is	wireless	technology, which	has	been	

tested	and	found	to	be	compliant	with	the	applicable	regulations	governing	a	radio	transmitter	in	the	

2.400GHz	to	2.4835GHz	frequency	range.	

Antenna	Separation	Distance	

When	operating	the	DJI	Inspire	1	transmitter,	the	PIC	will	maintain	a	separation	distance	of	at	least	5	cm	

between	his	body	(excluding	fingers,	hands,	wrists,	ankles	and	feet)	and	the	antenna	to	meet	RF	exposure	

safety	requirements	as	determined	by	FCC	regulations.	

Pilot	in	Command	and	Observer	Qualifications	and	Duties	The	PIC	will	maintain	at	least	a	Light	Sport	Pilot	

Certificate	and	a	current	State	issued	drivers	license,	plus	at	least	2	hours	flying	time	and	3	takeoffs	and	

landings	within	30	days	in	the	type	of	SUAS utilized	in	operations.	The	PIC	will	have	at	least	100	hours	

total	time	and	at	least	30	hours	flying	Radio	Controlled	Model	Aircraft,	of	which,	10	hours	will	be	flying	

SUAS.	The	PIC	is	responsible	for	the	safe	and	efficient	operation	of	the	aircraft.	Specific	duties	include	all	

preflight	preparation	and	inspection,	in	flight	operation,	post	flight	requirements,	and	all	procedures	

including	but	not	limited	to:	

- Safe	in	flight	operations	

- Risk	evaluation	

- Current	weather	conditions	for	safe	flight	
The	Observer	must	have	the	visual	acuity	to	observe	the	SUAS and	be	able	to	communicate	clearly	with	

the	PIC.	 The	Observers	duties	are:	

- Warning	the	PIC	of	any	impending	obstacles	in	the	flight	path	of	the	SUAS.	

- Warning	the	PIC	of	any	deviations	in	the	planned	flight	path	of	the	SUAS.	

- Warning	the	PIC	should	any	unauthorized	personnel	appear	in	the	area	of	the	planned	flight.	The	

Observer	will	have	the	authority	to	order	the	PIC	to	terminate	the	flight	should	he	feel	the	flight	can not	

be	conducted	safely.	

General	Operating	Standards	

•	Gani	Piñero	Photography,	LLC	will	only	operate	its	SUAS in	line	of	sight	of	a	pilot	and/or	observer	and	

will	operate	at	sites	that	are	a	'sufficient	distance'	from	populated	areas.	Such	operations	will	insure	that	

the	SUAS will	"not	create	a	hazard	to	users	of	the	national	airspace	system	or	the	public."	

•	Before	an	operation	of	a	SUAS within	5NM	of	an	airport	with	a	control	tower,	the	control	tower	will	be	

called	to	gain	permission	to	operate	the	SUAS.	The	PIC	will	give	the	position,	altitude	and	the	times	the	

sUAV	will	be	operated.	The	SUAS will	not	be	operated	at	an	altitude	of	over	200	feet	AGL.	Weather	

minimums	will	be	3	miles	visibility	and	a	1000	foot	ceiling.	

•	Before	an	operation	of	a	SUAS within	5NM	of	a	non-tower	controlled,	airport	operators	will	be	notified	

and	the	PIC	will	give	the	right	of	way to	avoid	flying	in	the	proximity	of	full- scale	aircraft.	At	no	time	will	

the	SUAS be	operated	within	the	final	approach	course	and	the	takeoff	course	of	any	runway.	The	sUAV	

will	not	be	operated	at	an	altitude	of	over	200	feet	AGL.	Weather	minimums	will	be	3	miles	visibility	and	a	

1000	foot	ceiling.	

•	Maximum	flight	time	for	each	operational	flight	will	be	18	minutes.	

•	Flights	will	be	terminated	at	30%	battery	power	reserve	should	that	occur	prior	to	the	18minute	limit.	

•	The	sUAV	will	be	programmed	so	that	it	will	not	be	operated	at	an	altitude	of	no	more	than	200	feet	

AGL,	and	not	more	than	200	feet	above	an	elevated	platform	from	which	filming	is	planned.	

•	Minimum	crew	for	each	operation	will	consist	of	the	SUAS Pilot,	and	Visual	Observer.	

•	The	sUAV	operated	by	the	petitioner	weighs	less	than	55	pounds,	including	the	payload	(i.e.	camera,	

lens,	and	gimbals).	

•	The	SUAS will	operate	at	speeds	of	no	more	than	25	knots,	can	hover,	and	can	simultaneously	move	

vertically	and	horizontally.	

•	Given	the	small	size	of	the	sUAV	and	the	restricted	sterile	environment	within	which	they	will	operate,	

our	sUAV	operations	adhere	to	the	Reform	Act's	safety	requirements.	The	SUAS,	powered	by	batteries,	is	

smaller,	lighter	and	more	maneuverable	than	larger	aircraft	running	on	combustible	fuel.	The	SUAS

operates	at	lower	altitudes	with	no	people	on	board	and	will	thereby	reduce	current	risk	levels,	enhance	

safety	and	diminish	the	likelihood	of	death	or	serious	bodily	injury.	With	a	small	payload	and	maximum	

flight	time	of	only	20	minutes,	this	offers	little	or	no	risk	to	national	security.	Low	level	oblique	photos	and	

video	from	several	angles	are	far	more	effective	than	ground	based	imagery	for	displaying	the	

characteristics	of	large,	complex	properties	with	several	buildings	and	large	trees.	The	benefits	of	reduced	

cost	and	improved	quality	of	presentation	from	the	SUAS over	manned	aircraft	will	be	valuable	to	and	

benefit	many	buyers	and	sellers	of	real	property,	farmers	and	ranchers,	and	local	city	officials	to	monitor	

our	local	water	supply.	Additionally,	we	request	that	we	be	allowed	to	use	our	system	to	benefit	first	

responders	nearby	who	might	require	assistance,	including	fire	fighters,	police,	sheriff,	etc.,	all	while	

remaining	subject	to	all	limitations	cited	below:	

(a)	No	flight	will	be	made	with	a	Gross	weight	exceeding	55	pounds;	

(b)	All	operations	must	occur	in	FAA	Class	G	airspace	at	no	more	than	200	ft	AGL,	at	an	airspeed	of	no	

more	than	25	knots	and	no	further	than	1600	ft,	or	0.263	NM	from	the	PIC;	

(c)	All	operations	must	utilize	a	visual	observer	(VO).	The	VO	and	PIC	must	be	able	to	communicate	by	

voice	at	all	times	during	a	flight	operation;	

(d)	Operations	will	be	restricted	to	flights	over	private	property	with	the	permission	of	the	property	

owner;	

(e)	All	required	permits	will	be	obtained	from	state	and	local	government	prior	to	operation;	

(f)	Gani	Piñero	Photography,	LLC	will	not	be	operating over	densely	populated	areas;	

(g)	Gani	Piñero	Photography,	LLC	will	not	be	operating	over	any	open-air	assembly	of	people;	

(h)	Gani	Piñero	Photography,	LLC	will	not	be	operating	over	heavily	trafficked	roads;	
(i)	Gani	Piñero	Photography,	LLC	will	not	be	operating	at	night.	

EXEMPTION	REQUESTS	AND	EQUIVALENT	LEVEL	OF	SAFETY	

Gani	Piñero	Photography,	LLC	requests	an	exemption	from	the	following	regulations	as	well	as	any	

additional	regulations	that	may	technically	apply	to	the	operation	of	the	sUAV	System:	

14	CFR	Part	21,	Airworthiness	Certificates	

This	part	establishes	the	procedures	for	the	issuance	of	an	airworthiness	certificate.	While	the	FAA	

continues	to	work	to	develop	airworthiness	standards	for	Unmanned	Aerial	Systems,	we	request	an	

experimental	certificate	be	issued	for	the	DJI	Inspire1	under	either	or	both	of	the	following	provisions:	

21.191	Experimental	certificates.	Experimental	certificates	are	issued	for	the	following	purposes:	

(a)	Research	and	development.	Testing	new	aircraft	design	concepts,	new	aircraft	equipment,	new	aircraft	

installations,	new	aircraft	operating	techniques,	or	new	uses	for	aircraft.	

(b)	Showing	compliance	with	regulations.	Conducting	flight	tests	and	other	operations	to	show	

compliance	with	the	airworthiness	regulations	including	flights	to	show	compliance	for	issuance	of	type	

and	supplemental	type	certificates,	flights	to	substantiate	major	design	changes,	and	flights	to	show	

compliance	with	the	function	and	reliability	requirements	of	the	regulations.	Since	the	experimental	

certificate	can	be	used	for	commercial	purposes	such	as	market	surveys,	sales	demonstrations,	and	

customer	crew	training,	we	would	expect	that	an	experimental	certificate	would	permit	our	commercial	

purpose	as	well.	The	aircraft	will	not	carry	persons	or	property,	will	not	carry	fuel,	and	will	only	fly	under	

strict	operational	requirements.	Combined	with	the	SUAS's	lightweight,	being	constructed	primarily	of	

carbon	fiber	and	plastic,	we	propose	that	the	SUAS will	be	at	least	as	safe,	if	not	safer,	than	a	

conventionally	certificated	aircraft	performing	the	same	mission.	If	an	experimental	airworthiness	

certificate	is	not	appropriate	for	this	application,	then	we	request	an	exemption	of	14	CFR	Part	21,	

Subpart	H,	and	the	requirement	for	an	airworthiness	certificate	in	general,	citing	the	equivalent	level	of	

safety	outlined	in	the	previous	paragraph.	

14	CFR	45.23	Display	of	marks;	general	and	45.29	Size	of	marks.	These	regulations	provide	that	each	

aircraft	must	display	"N"	and	the	aircraft's	registration	number	in	letters	at	least	3	inches	high.	

Additionally,	the	aircraft	must	display	the	word	"EXPERIMENTAL"	in	letters	at	least	2	inches	high	near	the	

entrance	to	the	cabin,	cockpit,	or	pilot	station.	The	SUAS does	not	have	an	entrance	in	which	the	word	

"EXPERIMENTAL"	can	be	placed,	and	may	not	have	a	registration	number	assigned	to	it	by	the	FAA.	We	

propose	to	achieve	an	equivalent	level	of	safety	by	including	the	word	"EXPERIMENTAL"	in	the	placard	on	

the	top	of	the	aircraft,	as	shown	above,	where	the	PIC	(Pilot	In	Control),	VO	(Visual	Observer)	and	others	

in	the	vicinity	of	the	aircraft	while	it	is	preparing	for	launch	will	be	able	to	see	the	designation.	

Additionally,	we	feel	that	the	permanent	placard	discussed	in	the	previous	paragraph	will	provide	the	

aircraft's	registration	information	at	the	ground	station.	Finally,	we	will	display	at	the	ground	station	a	

high	contrast	flag	or	banner	that	contains	the	words	"Unmanned	Aircraft	Ground	Station"	in	letters	3	

inches	high	or	greater.	Since	the	aircraft	will	operate	within	0.263	NM	of	the	ground	station,	the	banner	

should	be	visible	to	anyone	that	observes	the	aircraft	and	chooses	to	investigate	its	point	of	origin.	

14	CFR	61.113	Private	pilot	privileges	and	limitations:	Pilot	in	Command	and	61.133	Commercial	pilot	

privileges	and	limitations.	The	regulation	provides	that	no	person	that	holds	a	Private	Pilot	certificate	may	

act	as	pilot	in	Command	of	an	aircraft	for	compensation	or	hire.	Subparagraph	(b)	allows	a	private	pilot	to	

act	as	pilot	in	command	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.	Our	proposed	operations	require	that	the	PIC	must	hold	at	least	a	Private	Pilot	

Certificate	with	a	Class	III	Medical	issued	by	the	FAA	and	since	the	aircraft	cannot	carry	passengers	or	

property,	we	feel	we	meet	the	intent	of	61.113	Subparagraph	(b)	even	though	the	intent	of	this	

application	is	to	conduct	a	business.	

14	CFR	91.7	Prohibits	the	Operation	of	an	aircraft	without	an	airworthiness	certificate.	As	no	such	

certificate	will	be	applicable	in	the	form	contemplated	by	the	FARs,	this	Regulation	is	inapplicable.	

14	CFR	91.9	Civil	aircraft	flight	manual,	marking,	and	placard	requirements.	This	regulation	provides	that	

no	person	may	operate	an	aircraft	unless	a	current,	approved	flight	manual	is	in	the	aircraft.	We	assume	

that	the	intent	of	this	requirement	is	to	ensure	that	flight	manual	information	is	available	to	the	aircrew	

while	operating	the	aircraft.	We	request	an	exemption	to	this	requirement	since	the	aircraft	is	not	only	
too	small	to	carry	documentation,	the	documentation	would	not	be	available	to	the	crew	during	flight	

operations.	To	obtain	an	equivalent	level	of	safety	and	meet	the	intent	of	91.9,	we	propose	that	a	current,	

approved	SUAS Flight	Manual	must	be	available	to	the	crew	at	the	ground	station	anytime	the	aircraft	is	

in,	or	preparing	for,	flight,	and	ready	for	presentation	for	any	governing	official	upon	request.	

14	CFR	91.109	Flight	Instruction;	Simulated	instrument	flight	and	certain	flight	tests	The	regulation	states	

that	"No	person	may	operate	a	civil	aircraft	that	is	being	used	for	flight	instruction	unless	that	aircraft	has	

fully	functioning	dual	controls.	Although	the	DJI	Inspire	1	is	capable	of	duel/linked	controls,	Gani	Piñero	

Photography,	LLC	will	be	operating	with	a	single	remote	controller	as	well	as	a	second	in	operation	of	the	

camera	and	gimbal.	Isagani	Piñero of	Gani	Piñero	Photography,	LLC	will	be	the	only	pilot	in	control	of	the	

DJI	Inspire	1.	

91.119	Minimum	safe	altitudes:	General.	The	regulation	states	that	over	sparsely	populated	areas	the	

aircraft	cannot	be	operated	closer	than	500	feet	to	any	person,	vessel,	vehicle,	or	structure.	Since	the	

typical	mission	of	the	SUAS would	be	photography	or	survey	of	persons, vessels,	vehicles	or	structures	it	

would	be	necessary	to	operate	closer	than	500	feet	to	the	items	listed.	Operations	will	only	be	flown	over	

property	or	persons	where	permission	has	been	obtained	and	careful	pre- planned	flight	path	has	been	

performed.	The	aircraft	will	be	operated	at	a	low	altitude	allowing,	if	a	power	unit	fails,	an	emergency	

landing	without	undue	hazard	to	persons	or	property	on	the	surface.	Therefore	we	maintain	that	due	to	

the	small	size	of	the	SUAS,	the	hazard	to	persons,	vehicles	and	structures	is	minimal	compared	to	manned	

aircraft,	which	should	be	considered	in	granting	the	exemption.	

CFR	91.121	Altimeter	settings.	The	regulation	requires	that	aircraft	shall	maintain	cruising	altitudes	by	

reference	to	an	altimeter	setting	available	within	100	NM	of	the	aircraft.	The	SUAS will	always	fly	below	

200	feet	AGL	and	will	not	need	to	maintain	cruising	altitudes	in	order	to	prevent	conflict	with	other	

aircraft.	An	Above	Ground	Level	altimeter	measurement	above	the	takeoff	point	is	transmitted	via	radio	

from	the	SUAS on-board	computer	to	the	display	screen	held	by	the	PIC,	providing	a	constantly	updated	

AGL	readout.	

14	CFR	91.151	Fuel	requirements	for	flight	in	VFR	conditions.	The	regulation	provides	that	no	person	may	

begin	a	flight	in	an	airplane	under	day-VFR	conditions	unless	there	is	enough	fuel	to	fly	to	the	first	point	of	

intended	landing	and	to	fly	after	that	for	at	least	30	minutes.	We	feel	the	intention	of	this	paragraph	is	to	

provide	an	energy	reserve	as	a	safety	buffer	for	delays to	landing.	The	sUAV	is	battery	operated	and	the	

maximum	duration	of	flight	from	a	single	battery	charge	is	18	minutes	with	a	20%	reserve.	Since	the	

aircraft	will	never	fly	more	than	0.263	NM	from	the	point	of	intended	landing,	a	full	battery	charge	at	

launch	will	ensure	that	we	meet	the	reserve	energy	requirement	of	this	paragraph.	We	request	an	

exemption	to	the	word	"fuel"	and	ask	for	an	equivalent	interpretation	with	the	word	"energy".	

14	CFR	91.203(a)	&	(b)	Civil	aircraft:	Certifications	required.	The regulation	provides	that	an	airworthiness	

certificate,	with	the	registration	number	assigned	to	the	aircraft	and	a	registration	certificate	must	be	

aboard	the	aircraft.	Additionally,	subparagraph	(b)	provides	that	the	airworthiness	certificate	be	

"displayed	at	the	cabin	or	cockpit	entrance	so	that	it	is	legible	to	passengers	or	crew."	At	a	maximum	

gross	weight	of	6.47	pounds,	the	SUAS is	too	small	to	carry	documentation,	does	not	have	an	entrance,	

and	is	not	capable	of	carrying	passengers	or	crew.	To	obtain	an	equivalent	level	of	safety	and	meet	the	

intent	of	91.203,	we	propose	that	documents	deemed	appropriate	for	this	aircraft	by	the	FAA	will	be	with	

the	crew	at	the	ground	control	station	and	available	for	inspection	upon	request.	In	order	to	identify	the

aircraft,	we	propose	that	the	information	found	on	airworthiness	and	registration	certificates	be	

permanently	affixed	to	the	aircraft	via	placard	containing	the	following	information	plus	the	word	

"EXPERIMENTAL"	to	satisfy	the	requirement	of	

14	CFR	45.23.	14	CFR	Subpart	E	(91.401- 91.417)- Maintenance,	Preventive	Maintenance,	Alterations	The	

regulation	provides	that	the	operator	is	primarily	responsible	for	maintaining	the	aircraft	in	an	airworthy	

condition,	including	compliance	with	part	39	and	43.	Paragraphs	91.407	and	91.409	require	that	the	

aircraft	be	"approved	for	return	to	service	by	a	person	authorized	under	43.7"	after	maintenance	and	

inspection.	It	is	our	intention	that	the	PIC	perform	maintenance	and	inspection	of	the	aircraft	and	"be	

authorized to	approve	the	aircraft	for	return	to	service."	The	PIC	will	ensure	that	the	aircraft	is	in	an	

airworthy	condition	prior	to	every	flight	and	in	addition	conduct	detailed	inspections	after	every	two	

hours	of	flight.	Maintenance	performed	by	the	PIC	is	limited	to	repairing	small	cracks,	replacing	a	

propeller,	checking	electrical	connections	and	updating	software	and	firmware	for	the	on-board	
computer.	All	other	maintenance	will	be	performed	by	the	manufacturer	or	their	designated	repair	

facility.	The	PIC	will	document	work	performed	in	accordance	with	91.417.	We	feel	that	due	to	the	size,	

construction,	and	simplicity	of	the	aircraft,	the	PIC	can	ensure	an	equivalent	level	of	safety.	

Safety	and	Benefits	of	the	SUAS

Gani	Piñero	Photography,	LLC	will	be	using	the	SUAS in	a	variety	of	applications	that	generally	require	

expensive	full-size	manned	aircraft	to	complete.	Small,	light,	unmanned	aerial	vehicles	offer	more	

efficient	and	safer	benefits	over	the	use	of	full-sized	manned	aircraft	for	aerial	photography,	film	and	still	

photography,	and	real	estate	marketing.		By	granting	Gani	Piñero	Photography,	LLC’s	requested	

exemptions,	the	FAA	will	help	drive	development	of	safe	and	successful	commercial	SUAS operations	and	

will	advance	the	public	knowledge	base	for	such	operations.	Gani	Piñero	Photography,	LLC	is	committed	

to	promoting	the	SUAS research	efforts	of	policymakers	including	the	FAA,	NASA,	DOD	and	DARPA	by	

sharing	data	from	its	commercial	SUAS operations	and	serving	as	a	resource	for	future	SUAS research	

operations.	Thus,	the	FAA	has	good	cause	to	grant	this	Petition.	

Conclusion	

As	pointed	out	in	this	application,	the	DJI	Inspire1	which	our	company	would	use,	under	authorization	by	

the	US	DOT-FAA,	is	a	small,	light-weight	device	operated	within	the	line	of	sight	of	the	Pilot-in-Command	

(PIC),	less	than	200	feet	above	the	ground	and	outside	5	miles	from	any	airport,	heliport,	seaplane	base,	

spaceport,	or	other	location	with	aviation	activities,	unless	the	air	traffic	control	authorities	(ATC)	have	

been	notified	and	have	authorized	each	flight	within	a	radius	of	this	distance.	

The	DJI	Inspire1	has	been	proven	capable	for	controlled	flight.	It	is	a	SUAS offered	for	general	sale	on	the	

market	around	the	world	and	have	often	been	used	as	Model	Aircraft	in	the	USA.	We	are	certain	that	the	

studies	conducted	until	now	by	the	FAA,	about	Section	332,	Public	Law	112-95,	2014,	have	already	

provided	you	with	the	assurances	on	the	airworthiness	of	SUAS such	as	ours.	

For	the	foregoing	reasons,	the	exemptions	requested	herein	should	be	granted	and	Gani	Piñero	

Photography,	LLC	should	be	permitted	to	conduct	small	SUAS operations	in	accordance	with	its	manuals	

and	all	other	operating	parameters	deemed	necessary	and	appropriate	by	the	FAA.	

The	submission	of	this	application	and	its	contents	is	the	best	demonstration	that	indeed	it	is	possible	to	

pursue	the	authorization	process	so	that	some	SUAS may	be	used	for	legitimate	commercial	activities	and	

under	reasonably	safe	conditions.	

Signed	

Isagani	Piñero - Gani	Piñero	Photography,	LLC