UNITED STATES OF AMERICA 

DEPARTMENT OF TRANSPORTATION 

FEDERAL AVIATION ADMINISTRATION 

WASHINGTON, DC 

Regulatory Docket No. 

IN THE MATTER OF THE PETITION FOR EXEMPTION OF: 

Schulhof Marketing Group, Inc. 

FOR AN EXEMPTION SEEKING RELIEF FROM THE REQUIREMENTS OF 

TITLE 14 OF THE CODE OF FEDERAL REGULATIONS 

SECTIONS 21 subpart H, 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 

THE DJI INSPIRE 1 UNMANNED 

AIRCRAFT SYSTEM 

PURSUANT TO SECTION 333 OF 

THE FAA MODERNIZATION AND REFOR.M ACT OF 2012 

(PUBLIC LAW 112-95) 

Submitted on June 11, 2015 

Christopher Schulhof 

Schulhof Marketing Group, Inc. 

11216 Fall Creek Rd, Suite 100 

Indianapolis, IN 46256 

317-842-4747 
TABLE OF CONTENTS 

GLOSSARY OF ABBREVIATIONS 3 

SUMMARY 4 

INTRODUCTION AND INTEREST OF PETITIONERS 4 

., . 

•. ~ ~ • 1 ~ 

BASIS FOR PETITION 

NAME AND ADDRESS OF PETITIONERS 7 

THE SPECIFIC SECTIONS OF 14 C.F.R. FROM WHICH SCHULHOF MARKETING 

GROUP, INC. SEEKS EXEMPTION 8 

THE EXTENT OF RELIEF SCHULHOF MARKETING GROUP, INC. SEEK AND 

THE REASON SCHULHOF MARKETING GROUP, INC. SEEKS THE RELIEF 11 

THE REASONS WHY GRANTING REQUEST WOULD BE IN THE PUBLIC 

INTEREST 14 

THE REASONS WHY GRANTING THE EXEMPTION WOULD NOT 

ADVERSELY AFFECT SAFETY 16 

A SUMMARY THAT CAN BE PUBLISHED IN THE FEDERAL REGISTER 28 

CONCLUSION 29 

APPENDIX 30 

5 

m 

2 
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 

NOTCAM Notice To Airmen 

PIC Pilot In Command 

Section 333 FAA Modernization and Reform Act of 2012 (FMRA) 

Section 333 

SO Safety Observer 

SOP Standard Operating Procedure 

UA Unmanned Aircraft 

UAS Unmanned Aircraft System 

VFR Visual Flight Rules 

VLOS Visual Line Of Sight 

VMC Visual Meteorological Conditions 

VTOL Vertical Takeoff And Landing 

3 
SUMMARY 

Christopher Schulhof, owner of Schulhof Marketing Group, Inc., seeks exemption from the requirements of 

14 C.F.R §§ 21 subpart H, 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 

Schulhof Marketing Group, Inc. to operate an Unmanned Aircraft System (UAS) for the commercial purpose 

of conducting aerial video and photography to be used in real estate virtual tours, television and web based 

commercials, real estate promotion over certain areas of the United States. 

INTRODUCTION AND INTEREST OF THE PETITIONER 

Christopher Schulhof is the owner of Schulhof Marketing Group, Inc., located in Indianapolis, IN. Schulhof 

Marketing Group, Inc. was founded in 2006. Christopher Schulhof has 3 years of experience with RC flight 

and holds a CPR Certification. 

Schulhof Marketing Group, Inc. predominantly markets residential and commercial real estate in Indiana 

which includes homes, commercial buildings, land and area attractions. The objective of Schulhof Marketing 

Group, Inc. is to provide high quality imaging for a variety of commercial and public uses, specifically 

targeting: 

• Real Estate Photography 

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

4 
BACKGROUND 

Unmanned Aircraft Systems: DJI Inspire 1 UAS 

Schulhof Marketing Group, Inc. seeks an exemption to operate DJI systems for its own use and 

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

(VTOL) Unmanned Aircraft (UA) with a Ground Control Station (GCS) utilizing electronic tablet 

or smart phone systems. The DJI Inspire 1 has a maximum gross weight of 6 pounds 7.5 ounces, 

a length of 17.3 inches, width of 17.7 inches, height of 11.8 inches, and a maximum speed of 

approximately 42 knots. The DJI Inspire 1 UA is equipped with four main rotors; driven by 

Lithium Polymer battery powered electric motors. The DJI Inspire 1 UA that will be operated by 

Schulhof Marketing Group, Inc. will be registered in accordance with 49 U.S.C. 44103, 

Registration of Aircraft, as well as 14 C.F.R Part 47, Aircraft Registration, and marked in 

accordance with 14 C.F.R. Part 45, Identification and Registration Marking. 

BASIS FOR PETITION 

Petitioner, Christopher Schulhof of Schulhof Marketing Group, Inc. 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 petition 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 §§21 subpart H, 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, Schulhof Marketing Group, Inc.'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, Schulhof Marketing Group, Inc. 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. 

Schulhof Marketing Group, Inc. submits that the requested relief is proper since an equivalent level of 

safety will be ensured. Schulhof Marketing Group, Inc. will use experienced personnel or technicians 

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

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

DJI Inspire 1 Instruction Manual). Furthermore, Schulhof Marketing Group, Inc. will document and 

maintain all maintenance records for the DJI Inspire 1 UAS. 

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

limitations: Pilot in command, is requested by Schulhof Marketing Group, Inc. to the extent necessary 

to allow a Pilot in Command (PIC) holding an airman medical certificate, and who has demonstrated, 

by meeting minimum flight- hour and currency requirements, that the PIC is able to safely operate the 

DJI Inspire 1 UAS in a manner consistent with this exemption, including evasive and emergency 

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

Schulhof Marketing Group, Inc. 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, Schulhof Marketing Group, Inc. 

submits that they will ensure that the DJI Inspire 1 UAS is in an airworthy condition, prior to 

every flight, by determining that the UAS are in compliance with the operating documents 

(i.e., Monthly Maintenance Log, and DJI Inspire I Instruction Manual), and that the aircraft 

are in a condition for safe flight. 

Schulhof Marketing Group, Inc. also seeks an exemption from the requirements of Section 

91.121, entitled Altimeter Settings, as the DJI Inspire 1 UA will not have a typical barometric 

altimeter onboard. However, altitude information of the DJI Inspire lUA 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 Schulhof Marketing Group, Inc.'s 

operation of the DJI Inspire 1 UA within visual line of sight, at or below 400 feet AGL, will 

ensure a level of safety equivalent to Section 91.121. 

Additionally, Schulhof Marketing Group, Inc. seeks an exemption from the requirements of 

Section 91.151(b), entitled Fuel reqatirements for, flight in YFR conditions. Schulhof 

Marketing Group, Inc. submits that safety will not be affected by operation of the DJI Inspire 

I UA 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 13.5 

minutes to the first point of intended landing and, assuming normal cruising speed, to fly 

after that for at least 4.5 minutes. 

In accordance with 14 C.F.R. § 11.81, Schulhof Marketing Group, Inc. provides the 

following information in support of their petition for exemption: 

6 
A. Name and Address 4f The Petitioner 

Christopher Schulhof 

Schulhof Marketing Group, Inc. 

11216 Fall Creek Rd, Suite 100 

Indianapolis, IN 46256 

chris@indyplace.com 
B. The Specific Sections Of 14 C.F.R. From Which Schulhof Marketing 

Group, Inc. Seeks Exemption. 

1. Schulhof Marketing Group, Inc. Seeks Exemption From The Requirements Of 

Section Part 21, Subpart H 

14 C.F.R. Part 21, Subpart H, establishes the procedural requirements for the issuance of 

airworthiness certificates as required by 14 C.F.R. §91.203(a)(1) 

2. Schulhof Marketing Group, Inc. 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. 

3. Schulhof Marketing Group, Inc. 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. 

4. Schulhof Marketing Group, Inc. 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. 

5. Schulhof Marketing Group, Inc. Seeks Exemption From The 

Requirements Of Section 91.151(b). 

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

states the following: 

(b) No person may begin a flight in a rotorcraft tcnder VFR conditions unless 8 
(considering wind and forecast weather conditions) there is enoicgh fitel to fly to the first 

point of intended landing and, assctming normal cruising speed, to f1'y after that for at least 

20 minittes. 

6. Schulhof Marketing Group, Inc. 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[.] 

7. Schulhof Marketing Group, Inc. 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[.] 

8. Schulhof Marketing Group, Inc. 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. 

9. Schulhof Marketing Group, Inc. 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— 
(1) 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)( I) of this section shall be retained until the work 

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

(2) The records specified in paragraph (a)(2) of this section shall be retained and 

transferred with the aircraft at the time the aircraft is sold. 

(3) A list of defects furnished to a registered owner or operator under § 43.11 of this 

chapter shall be retained until the defects are repaired and the aircraft is approved for 

return to service. 

10 
C. The Extent Of Relief Schulhof Marketing Group, Inc. Seeks And 

The Reason Schulhof Marketing Group, Inc. Seeks The Relief. 

1. Schulhof Marketing Group, Inc. Seeks Exemption From The Requirements Of 

Section Part 21, Subpart H 

Given the size and limited operating area associated with the UAS to be utilized by the 

Schulhof Marketing Group, Inc., an exemption from Part 21 Subpart H meets the 

requirements of an equivalent level of safety under Part 11 and Section 333 of the Reform 

Act. 

The Federal Aviation Act (49 U.S.C.§ 44701(f)) and Section 333 of the Reform Act both 

authorize the FAA to exempt aircraft from the requirement for an airworthiness certificate, 

upon consideration of the size, weight, speed, operational capability, and proximity to 

airports and populated areas of the particular UAS. 

In all cases, an analysis of these criteria demonstrates that the UAS operated without an 

airworthiness certificate, in the restricted environment and under the conditions proposed 

will be at least as safe, or safer, than a conventional rotorcraft operating with an 

airworthiness certificate without the restrictions and conditions of the proposed UAS 

operations. 

2. Extent Of Relief Schulhof Marketing Group, Inc. Seeks And The Reason 

Schulhof Marketing Group, Inc. 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 valid airman 

medical certificate, and who has met certain flight-hour and currency requirements, to 

conduct the proposed UAS flight operations for compensation or hire. 

This relief is requested since the limitations set forth in Section 61.113(a) and (b) state that a 

private pilot may, for compensation or hire, act as PIC of an aircraft in connection with any 

business or employment if: (1) The flight is only incidental to that business or employment; 

and (2) The aircraft does not carry passengers or property for compensation or hire. 

As set forth more fully below, Schulhof Marketing Group, Inc. submits that an equivalent 

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

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

that the PIC is able to safely operate the DJI Inspire I 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, Schulhof Marketing Group, Inc. 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 Schulhof 

Marketing Group, Inc.'s business; and (2) will not carry passengers or property for 

compensation or hire. 

11 
3. Extent Of Relief Schulhof Marketing Group, Inc. Seeks And The Reason 

Schulhof Marketing Group, Inc. 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 Schulhof Marketing Group, Inc. to determine that the DJI Inspire 1 UAS 

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

with the operating documents (i.e., the Monthly Maintenance Log, and DJI Inspire 1 

Instruction Manual). 

Schulhof Marketing Group, Inc. seeks the requested relief because the DJI Inspire 1 U A 

does not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart 

H. Therefore, Schulhof Marketing Group, Inc. will ensure that the DJI Inspire 1 UAS is in 

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

Maintenance Log, and DJI Inspire 1 Instruction Manual) prior to every flight, and further, 

determine that the aircraft are in condition for safe flight, as stated in the conditions and 

limitations below. 

4. Extent Of Relief Schulhof Marketing Group, Inc. Seeks And The Reason 

Schulhof Marketing Group, Inc. 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 station (GCS). Since the FAA requires that any 

altitude information concerning UAS operations be reported to air traffic control (ATC) in 

feet above ground level (AGL), Schulhof Marketing Group, Inc. 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 UA is equipped with a barometric pressure sensor and GPS equipment, 

which automatically ensures that a ground level pressure setting will be established prior to 

each flight, and provides the PIC with altitude information of the UA on the heads-up display 

of the GCS. 

5. Extent Of Relief Schulhof Marketing Group, Inc. Seeks And The Reason 

Schulhof Marketing Group, Inc. Seeks Relief From Section 91.151(b). 

Relief from Section 91.151(b) entitled Fuel requirements for flight in VFR conditions, is 

requested to the extent required to allow flights of the battery powered DJI Inspire 1 UA 

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

(VFR), for a total duration of 13.5 minutes to the first point of intended landing and, 

12 
assuming normal cruising speed, to fly after that for at least 4.5 minutes. Schulhof Marketing 

Group, Inc. seeks the requested relief because without an exemption from Section 91.151(b), 

the flight time duration of the battery powered DJI Inspire 1 UA will severely constrain the 

practicality of any aerial video or still photo flight operations that Schulhof Marketing 

Group, Inc. 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 Schulhof Marketing Group, Inc.'s proposed 

operating limitations, ensure that Schulhof Marketing Group, Inc. will safely operate the 

battery powered DJI Inspire 1 UA during daylight hours in visual meteorological conditions 

(VMC), under visual flight rules (VFR), with enough battery power to fly for a total duration 

of 13.5 minutes to the first point of intended landing and, assuming normal cruising speed, to 

fly after that for at least 4.5 minutes. 

6. Extent Of Relief Schulhof Marketing Group, Inc. Seeks And The Reason 

Schulhof Marketing Group, Inc. 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, Schulhof Marketing Group, Inc. requests 

relief from these Sections 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, Schulhof 

Marketing Group, Inc. will use trained technicians to perform maintenance, alterations, or 

preventive maintenance on the UAS using the methods, techniques, and practices prescribed 

in the UAS operating documents (i.e., Monthly Maintenance Log, and DJI Inspire 1 

Instruction Manual). Furthermore, Schulhof Marketing Group, Inc. will document and 

maintain all maintenance records for the DJI Inspire 1 UAS. 

13 
D. The Reasons Why Granting Schulhof Marketing Group, Inc.'s Request 

Would Be In The Public Interest; or How It Would Benefit The Public As A 

Whole. 

Granting the present petition will further the public interest by allowing Schulhof Marketing 

Group, Inc. to safely, efficiently, and economically perform aerial video and photography of 

wilderness, real estate, and landscapes over certain areas of the United States. Furthermore, it 

will benefit the public as a whole by increasing awareness for the wild lands, therefor 

increasing tourism, and stimulating the economy of a highly tourism dependent area. 

Additionally, use of the DJI Inspire 1 UAS will decrease congestion of the NAS, and reduce 

pollution. Notably, the benefits of Schulhof Marketing Group, Inc.'s proposed operation of 

the DJI Inspire 1 UAS will be realized without implicating any privacy issues. 

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

The DJI Inspire 1 UAs are battery powered and serve as a safe, efficient, and economical 

alternative to the manned aircraft traditionally utilized to obtain aerial imagery. By reducing 

the amount of manned aircraft needed to perform aerial acquisitions, an exemption allowing 

the use of a DJI Inspire 1 UAS would reduce the amount of manned aircraft in the NAS, 

reduce noise and air pollution, as well as increase the safety of life and property in the air and 

on the ground. 

Furthermore, by reducing the number of manned aircraft operating in the NAS, congestion 

around airports caused by arriving and departing aircraft will be reduced. The DJI Inspire 1 

UAs do not require an airport to takeoff or land. Likewise, a reduction of manned aircraft 

conducting aerial video and photography missions would result in fewer aircraft that must be 

handled by air traffic control during the ground, takeoff, departure, arrival, and landing 

phases of flight operations. 

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, instead of manned aircraft, will 

greatly benefit the public by drastically reducing the levels of air and noise pollution 

generated during traditional aerial video and still photography flight operations. By using 

battery power and electric motors, the DJI Inspire I UAS produces no air pollution, and is the 

most viable environmentally conscious alternative to the cabin class, six cylinder internal 

combustion engine aircraft that are typically utilized for aerial video and photography, while 

burning approximately 20-30 gallons per hour of leaded aviation fuel. The DJI Inspire 1 UA, 

while reducing the carbon footprint of aerial acquisitions, also eliminates noise pollution, as 

the UAs are propelled by battery powered electric motors, rather than an intemal combustion 

engine. 

By using the DJI Inspire 1 UAS to perform aerial acquisitions, the substantial risk to life and 

property in the air and on the ground, which is usually associated with traditional manned 

aircraft flight operations, will be substantially reduced or completely eliminated. 

14 
Aside from the lack of flight crew members located onboard the aircraft, the DJI Inspire 1 

UA (weighing approximately 6 pounds 7.5 ounces respectively, at its maximum gross 

weight with a length of 17.3 inches and width of 17.7 inches, and with no fuel on board), has 

less physical potential for collateral damage to life and property on the ground, and in the 

air, compared to the manned aircraft that typically conduct similar operations (weighing 

approximately 6,000 pounds with a wingspan of approximately 42 feet, a length of 34 feet, 

and a fuel capacity of 180 gallons). 

3. Performing Aerial Video and Photography Operations With The DJI Inspire 1 UAS 

Will Benefit The Economy. 

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

alternative to using manned aircraft to conduct similar aerial operations. As such, operation 

of the DJI Inspire 1 UAS will allow United States based companies, like Schulhof Marketing 

Group, Inc., to remain competitive and contribute to growth of the U.S. economy. 

Specifically, with the rising cost of aviation fuel and the Environmental Protection Agency 

("EPA") regulatory actions phasing out leaded aviation fuels, U.S. owned and operated 

companies must adopt new and alternative technology in order to remain competitive. 

Operating the battery powered DJI Inspire 1 UAS is one such technology that not only 

allows companies greater operational flexibility compared to manned aircraft, but provides 

such flexibility without the high operational cost of a traditional manned aircraft. 

By operating the DJI Inspire 1 UAS, companies such Schulhof Marketing Group, Inc., can 

remain competitive and profitable, and therefore, provide greater job stability to employees 

and contractors, which will ultimately contribute to growth of the U.S. economy. Improved 

financial performance of U.S. companies, through commercial use of the DJI Inspire 1 UAS, 

provides a stable workforce that increases consumer spending; improves local, state, and 

federal tax revenues; and allows companies to invest in research and development in order to 

remain competitive both in the United States and abroad. 

Additionally, by allowing operation of the DJI Inspire 1, Schulhof Marketing Group, Inc. 

will be able to more easily work with local and state tourism agencies to showcase the 

beauty and wildness of a very tourism based economy, therefor improving the economy of 

both state and local businesses. 

4. There Are No Privacy Issues. 

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

decades, Schulhof Marketing Group, Inc.'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 (i.e., Monthly Maintenance Log, and DJI Inspire 1 

Instruction Manual), which requires property owner involvement as well as local law 

enforcement notification, and in accordance with the Federal Aviation Regulations, 

including the minimum altitude requirements of 14 C.F.R. §91.119. 

15 
E. The Reasons Why Granting The Exemption Would Not Adversely 

Affect Safety, Or How The Exemption Would Provide A Level Of Safety 

At Least Equal To That Provided By The Rule From Which Schulhof 

Marketing Group, Inc. Seeks Exemption. 

1. Reasons Why The DJI Inspire 1 UA 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, Schulhof Marketing Group, Inc.s's operation of the DJI 

Inspire 1 UAS meets the conditions of FMRA Section 333, and will not require an 

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

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

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

NAS or the public, or otherwise pose a threat to national security. Specifically, FMRA 

Section 333 states the following, in part: 

(a) In General .--Notwithstanding any other reqatirement of this satbtitle, and not later than 

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

determine if certain icnmanned aircraft systems may operate safely in the national airspace 

system before completion of the 

plan and riclemaking required by section 332 of this Act or the gacidance required by section 

334 of this Act. 

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

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 sectcrity; and 

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

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

operation of unmanned aircraft systems identif ed 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, Schulhof Marketing Group, Inc. 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 Demonstrates Its Safe 

Characteristics. 

16 
The DJI Inspire 1 UAS does not create a hazard to users of the NAS or the public, or 

otherwise pose a threat to national security considering its size, weight, speed, and 

operational capability. 

i. Technical Specifications Of The DJI Inspire 1 UAS. 

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

Specifications and Data Sheet. 

ii. The DJI Inspire 1 UAS Autonomous Flight And Navigation Modes Enable The UAS 

To Remain Within A Defined Operational Area. 

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

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

provided at pages 12-16 and 45-50 of the DJI Inspire 1 User Manual, attached hereto as 

Exhibit B. 

iii.The DJI Inspire I 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 UA will remain stationary, in flight, for 3 

seconds or more. If, after 3 seconds, DJI Inspire 1 UA do not reacquire control link data from 

the GCS, the UA will assume that the Control Link is lost and the UA 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 through 15 of the DJI Inspire 1 User Manual, attached hereto as Exhibit A. 

iv. The DJI Inspire I GCS And Its Operation. 

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

flight control software is provided at pages 40 through 47 of the DJI Inspire 1 User Manual. 

DJI Inspire 1 User Manual is attached hereto as Exhibit A. 

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

Certificated Pilot in Command With A Safety Observer. 

Schulhof Marketing Group, Inc. will only utilize certificated pilots to act as a pilot in 

command (PIC) of the DJI Inspire 1 UAS. Additionally, a safety observer will assist all 

pilots during flight time. 

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

Operating Limitations. 

In seeking this exemption, Schulhof Marketing Group, Inc. proposes to commercially 

operate the 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 

17 
aircraft described in the operating documents, rotorcraft UASs weighing less than 55 

pounds 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 UAs 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 UAs 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. 

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

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

18 
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, 

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 meet possess at least a current medical certificate. 

18. The operator may not permit any PIC to operate unless the PIC meets the operator's 

qualification criteria and demonstrates the ability to safely operate the UAS in a manner 

consistent with how the UAS will be operated under the exemption, including evasive and 

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

and structures. PIC qualification flight hours must be logged in a manner consistent with 14 

C.F.R. § 61.51(b). Flights for the purposes of training the operator's PICs are permitted 

under the terms of the exemption. However, training operations may only be conducted 

during dedicated training sessions. During training, proficiency, and experience-building 

flights, all persons not essential for flight operations are considered non-participants, 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 

19 
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 more than 400 feet above or more than 2,000 feet 

horizontally from the PIC 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. 

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. 

20 
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 opei- ated by the PIC f'rom any moving device oi -vehicle. 

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

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

vessels, vehicles, and structures unless: 

a. Barriers or structures are present that sufficiently protect nonpai - ticipating 

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 ancl are witllin 500 f'ect 

of the UA, flight operations must cease immediately and/oi - ; 

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

owner/conti-oller 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, opet - ator trainees or essential persons do not 

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

32. A11 operations shall be conducted over private or controlled-aeeess property with 

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

from land owner/conti-oller oi-authorized representative will be obtained for each 

flight to be conducted. 

33.Any incident, accident, or flight operation that transgresses the latei - al or vet- tical 

boundaries of the operational area as defined by the applicable COA inust 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 . 

21 
2. Reasons Why An Exemption From The Requirements Of Section 21 Subpart H 

Would Not Adversely Affect Safety. 

Schulhof Marketing Group, Inc. submits that the equivalent level of safety established by 

Section 61.113(a) and (b) will be maintained because The UAS to be operated hereunder 

weighs less than 551bs. fully loaded, carries neither a pilot nor passenger, carries no 

explosive materials or flammable liquid fuels, and operates exclusively within a secured 

area. Unlike other civil aircraft, the proposed operations in this petition for exemption will 

be controlled and monitored by the operator, pursuant to the Manual's requirements. 

These safety enhancements, which already apply to civil aircraft operated in connection with 

existing inspection operations, provide a greater degree of safety to the public and property 

owners than conventional operations conducted with airworthiness certificates issued under 

14 C.F.R. Part 21, Subpart H. Lastly, application of these same criteria demonstrates that 

there is no credible threat to national security posed by the UAS, due to its size, speed of 

operation, location of operation, lack of explosive materials or flammable liquid fuels, and 

inability to carry a substantial external load. 

3. Reasons Why An Exemption From The Requirements Of Section 61.113(a) And 

(b)Would Not Adversely Affect Safety. 

Schulhof Marketing Group, Inc. submits that the equivalent level of safety established by 

Section 61.113(a) and (b) will be maintained because no PIC will be allowed to operate the 

DJI Inspire 1 UAS unless that PIC has demonstrated, by meeting minimum flight-hour and 

currency requirements, that the PIC is able to safely operate the DJI Inspire 1 UAS in a 

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

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

Considering Schulhof Marketing Group, Inc.'s proposed area of operations, and the 

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

knowledge requirements to those of commercial pilot requirements (See Exemption No. 

11062); and the airmanship skills necessary to safely operate the DJI Inspire 1 UAS, 

Schulhof Marketing Group, Inc. submits that the additional manned airmanship experience 

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

Schulhof Marketing Group, Inc.'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). 

Schulhof Marketing Group, Inc. 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 

22 
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 Schulhof Marketing Group, Inc.'s proposed operations. The Administrator has 

held that prior documented flight experience that was obtained in compliance with applicable 

regulations would ensure safe operations, stating as follows: 

In Exemption No. 11062, the FAA required that prior to conducting operations for the 

purpose of motion picture filming (or similar operations), the PIC must have accumulated 

and logged, in a manner consistent with 14 CFR 61.51(b), 25 hours of total time as a UAS 

rotorcraft pilot including at least 10 hours logged as a UAS pilot with a multi-rotor UAS. 

Prior to operations under Exemption No. 11062, the PIC must also have accumulated and 

logged a minimum of 5 hours as a UAS pilot operating the same make and model of UAS to 

be used for operations under the exemption. For clarification, the FAA considers these 

minimum hour requirements to be inclusive rather than additive; i.e. 5 hours make and model 

time may be included in the 10 hours of multi-rotor time and the 10 hours may be included in 

the tota125 hours of UAS rotorcraft time. In addition to the hour requirements, the PIC must 

accomplish 3 takeoffs and landings in the preceding 90 days (for currency purposes). The 

FAA finds that at a minimum, the flight-hour requirements in Exemption No. 11062 are 

appropriate to practice and build proficiency in the skills necessary to safely conduct the 

petitioner's proposed operations. The FAA also finds that prior documented flight experience 

that was obtained in compliance with applicable regulations would satisfy this requirement. 

Training, proficiency, and experience-building flights can also be conducted under the grant 

of exemption to accomplish the required flight time. During training, proficiency, and 

experience-building flights the PIC is required to operate the UA with appropriate distances 

in accordance with 14 C.F.R 91.119. 

Exemption No. 11138 at page 15. 

Accordingly, Schulhof Marketing Group, Inc. 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. 

4. Reasons Why An Exemption From The Requirements Of Section 91.7(a) Would 

23 
Not Adversely Affect Safety. 

The equivalent level of safety established by Section 91.7(a) will be maintained because 

prior to every flight, Schulhof Marketing Group, Inc. 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 9 11156, 11157 9 11158, 11159,11160, 11161). 

5. 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 U A will be provided to the PIC via GPS equipment 

and a radio communications telemetry data link, which downlinks from the UA to the GCS 

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

with Schulhof Marketing Group, Inc.'s operation of the DJI Inspire 1 U A 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. 110621 11063, 11064,11065, 11066, 11067, 11080, 11109, 11112, 11136, 11138, 

11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161). 

6. 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, Schulhof Marketing Group, Inc. will ensure that it 

will safely operate the battery powered DJI Inspire 1 U A during daylight hours in VFR 

conditions, with enough battery power to fly for a total duration of 13.5 minutes to the first 

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

4.5 minutes. 

Here, as in Exemption No. 11109, the technical specifications of the DJI Inspire 1 UAS; 

24 
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 provides audible 

and visual warnings to the PIC at the GCS when the UA 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). 

7. Reasons Why An Exemption From The Requirements Of Sections 91.405(a), 

91.407(a)(1), 91409(a)(1) &(a)(2), And 91.417(a) &(b) Would Not Adversely Affect 

Safety. 

In seeking this exemption, Schulhof Marketing Group, Inc. 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 Schulhof Marketing Group, Inc. will use trained technicians to perform 

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

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

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

Marketing Group, Inc. will document and maintain all maintenance records for the DJI 

Inspire 1 UAS. 

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

Schulhof Marketing Group, Inc. will maintain the equivalent level of safety established by 

Sections 91.405(a), 91.409(a)(1), and 91.409(a)(2). A copy of the DJI Inspire 1 User Manual 

is attached hereto as Exhibit C and D; a copy of the DJI Inspire 1 UAS Maintenance LOG is 

attached hereto as Exhibit C. 

Likewise, the exemption sought will not adversely affect safety because Schulhof Marketing 

Group, Inc. will use trained technicians to perform maintenance, alterations or preventive 

maintenance on the UAS using the methods, techniques, and practices prescribed by the 

operating documents. 

Furthermore, the exemption sought would maintain an equivalent level of safety established 

by Sections 91.407, 91.417(a) and 91.417(b), because all maintenance of the DJI Inspire 1 

UAS will be performed by trained technicians. Maintenance will be documented and 

maintained utilizing the monthly maintenance log. Previous exemptions 

25 
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 

Schulhof Marketing Group, Inc. proposed operating limitations, the operating documents, 

and the technical aspects of the DJI Inspire 1 UAS, Schulhof Marketing Group, Inc. 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, 

110809 11109, 11110,11112, 11136, 11138, 11150, 11153,11156,11157, 11158,11159, 

11160,11161). 

8. The FAA May Prescribe Any Other Conditions For Safe Operation. 

In accordance with Section 333 of the FAA Modernization and Reform Act of 2012 

(FMR.A) and 14 C.F.R. § 21.16 entitled Special Conditions, Schulhof Marketing Group, Inc. 

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. FMR.A 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 Schulhof Marketing Group, Inc. intended operation of the 

DJI Inspire 1 

26 
UAS, which contain such safety standards that the Administrator finds necessary to 

establish a level of safety equivalent to that established by 14 C.F.R. Part 21, Subpart H, 

and 14 C.F.R Sections 61.113(a) &(b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 

91.409(a)(1) & (a)(2), and 91.417(a) & (b). 

27 
F. A Summary That Can Be Published In The Federal Register, stating: 

The Rules From Which Schulhof Marketing Group, Inc. Seeks Exemption: 

Schulhof Marketing Group, Inc. seeks exemption from the requirements of 14 C.F.R 

Sections 21 Sacbpart H, 61.113(a)&(b), 91. 7(a), 91.121, 91.151(b), 91.405(a), 

91.407(a) (1), 91.409(a) (1) & (a) (2), and 91.417(a) & (b). 

A Brief Description Of The Nature Of The Exemptions Schulhof Marketing Group, Inc. 

Seeks: 

This exemption will permit Schulhof Marketing Group, Inc. to commercially operate an 

Unmanned Aircraft System (UAS) for the purpose of condiccting aerial video and 

photography over certain areas of the United States. 

Any Additional Information, Views, Or Arguments Available To Support Schulhof 

Marketing Group, Inc. Request. 

This Petition is made pursuant to the FAA Modernization and Reform Act of 2012 (FMRA) 

Section 333, which directs the Secretary of Transportation to determine if certain UAS may 

operate safely in the NAS. As such, Schulhof Marketing Group, Inc.'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, Schulhof Marketing Group, Inc. 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. 

28 
CONCLUSION 

As set forth herein, Schulhof Marketing Group, Inc. 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 Schulhof 

Marketing Group, Inc. to safely, efficiently, and economically operate the DJI Inspire 1 

UASs commercially within the NAS. 

In accordance with the Federal Aviation Regulations and the FAA Modernization and 

Refonn Act of 2012, Section 333, Schulhof Marketing Group, Inc. respectfully requests that 

the Administrator grant this Petition for an exemption from the requirements of 14 C.F.R 

Sections 21 Subpart H, 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 Schulhof Marketing Group, Inc. to 

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

photography over certain areas of the United States. 

Dated: June 11, 2015 

Respectfully, 

~ 

Christopher Schulhof 

Schulhof Marketing Group, Inc. 

11216 Fall Creek Rd, Suite 100 

Indianapolis, IN 46256 

29 
Appendices: 

A- DJI Inspire 1 Specifications Data Sheet 

APPENDIX-A 

DJI INSPIRE 1 TECHNICAL SPECIFICATIONS 

Schulhof Marketing Group, Inc. only utilizes safe and reliable UASs. DJI is an industry 

leader in small UAS production. DJI UASs are loaded with ground breaking software 

enabling the user to set parameters which will not allow flight into controlled airspace. 

Parameters can also be set to limit flight to no higher than a predetermined and set altitude as 

well as limit flight to a predetermined and set distance. In addition, DJI software provides 

real-time altitude and location infonnation to the PIC via the linked monitor (smart 

phone/tablet devices) 

2.2 DJI Inspire 1 

2.2.1 Aircraft 2.2.1.1 Model - T600 

2.2.1.2 Weight (Battery Included) - 61bs 7.5291 oz (2935g) 

2.2.1.3 Hovering Accuracy (GPS Mode) - Vertical: 0.5m; Horizontal: 2.5m 

2.2.1.4 Max Angular Velocity - Pitch: 3000/s; Yaw: 1500/s 

2.2.1.5 Max Tilt Angle - 350 

2.2.1.6 Max Ascent Speed - 5m/s 

2.2.1.7 Max Descent Speed - 4m/s 

2.2.1.8 Max Speed - 22m/s (ATTI mode, no wind - NOT RECOMMENDED) 

2.2.1.9 Max Flight Altitude - 4500m 

2.2.1.10 Max Wind Resistance — 10 m/s 

2.2.1.11 Max Flight Time - Approximately 18 minutes 

2.2.1.12 Motor Model - DJI 3510 

2.2.1.13 Propeller Model - DJI 1345 

2.2.1.14 Operating Temperature Range - HOF to 1040F (- l 00C to 400C) 

2.2.1.15 Dimensions - 17 1/4' x 17 W' x 12" 

2.2.2 Gimba12.2.2.1 Model - ZENMUSE X3 

2.2.22 Output Power (with camera) - Static: 9W; In Motion: 11 W 

2.2.2.3 Operating Current - Static: 750mA; In Motion: 900mA 

2.2.2.4 Angular Vibration Range - f0.030 

2.2.2.5 Mounting - Detachable 

2.2.2.6 Controllable Range - Pitch: -900to +300; Pan: f3200 

2.2.2.7 Mechanical Range - Pitch: -1250to 450; Pan: f3300 

2.2.2.8 Max Controllable Speed - Pitch: 1200/s; Pan: 1800/s 

2.2.3 Camera 2.2.3.1 Name - X3 

2.2.3.2 Model-FC350 

2.2.3.3 Total Pixels - 12.76M 

2.2.3.4 Effective Pixels - 12.4M 

2.2.3.5 Image Max Size - 40000000 

2.2.3.6 ISO Range - 100-3200 

30 
2.2.3.7 Field of View-940 

2.2.3.8 CMOS - Sony EXMOR 1/2.3" 

2.2.3.9 HD Video Recording - UHD(4K): 4096x2160p24/25, 3840x2160p24/25/30; 

FHD: 1920x1080p24/25/30/48/50/60; HD: 1280020p24/25/30/48/50/60 

2.2.3.10Operating Temperature Range - 320F - 1040F (OOC - 400C) 

2.2.4 Transmitter 2.2.4.1 Name - C 1 

2.2.4.2 Operating Frequency - 5.728-5.850GHz; 2.400-2.483GHz 

2.2.4.3 Communicating Distance (unobstructed) - 2000m 

2.2.4.4 Output Power - 9W 

2.2.4.5 Operating Temperature Range - 140F to 1040F (- l 00C to 400C) 

2.2.4.6 Battery - 600mAh LiPo 2S 

B- DJI Inspire 1 User Manual 

31 
APPENDIX-B 

DJI INSPIRE 1 USER MANUAL 

http://download.di i-innovations.com/downloads/inspire_1/en/Inspire_I_User_Manual_v1.2_en.pdf 

32 
C- DJI Inspire 1 Maintenance Log 

APPENDIX -C 

DJI INSPIRE I Maintenance Log 

Monthly Maintenance Log 

UAS # 

Date Issue 

Discovered 

Date issue 

Addressed 

Issue Description & 

Maintenance 

Concluded Maintenance Performed By: 

Softwa re 

Updates 

Airframe 

Engines 

Propellers 

Camera 

Gimbal 

Landing Gear 

Vibration 

Dampening 

Other: 

33