UNITED STATES OF AMERICA

DEPARTMENT OF TRANSPORTATION

FEDERAL AVIATION ADMINISTRATION

WASHINGTON, DC

Regulatory Docket No. _______________

IN THE MATTER OF THE PETITION FOR EXEMPTION OF:

Ryan Wells, DBA OK Real Estate Photography

FOR AN EXEMPTION SEEKING RELIEF FROM THE REQUIREMENTS OF

TITLE 14 OF THE CODE OF FEDERAL REGULATIONS

SECTIONS 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1),

91.409(a)(1) & (a)(2), AND 91.417(a) & (b) CONCERNING COMMERCIAL 

OPERATION OF DJI INSPIRE 1 UNMANNED AIRCRAFT SYSTEM

PURSUANT TO SECTION 333 OF THE FAA MODERNIZATION AND REFORM ACT 

OF 2012 (PUBLIC LAW 112-95)

Submitted on: June 24, 2015

Ryan Wells

DBA: OK Real Estate Photography

8501 Curtis Terrace

Oklahoma City, OK

Tel: (405) 664-7885
TABLE OF CONTENTS

Page

GLOSSARY OF 

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

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

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

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

BASIS FOR 

PETITION.................................................................................................5

NAME AND ADDRESS OF PETITIONER..................................................7

THE SPECIFIC SECTIONS OF 14 C.F.R. FROM WHICH Ryan Wells, DBA OK Real 

Estate Photography

SEEKS EXEMPTION.................................................................8

THE EXTENT OF RELIEF Ryan Wells, DBA OK Real Estate Photography SEEKS AND 

THE REASON

Ryan Wells, DBA OK Real Estate Photography SEEKS THE RELIEF....................11

THE REASONS WHY GRANTING Ryan Wells, DBA OK Real Estate Photography’S 

REQUEST WOULD

BE IN THE PUBLIC INTEREST .........................................................15

THE REASONS WHY GRANTING THE EXEMPTION WOULD NOT ADVERSELY

AFFECT SAFETY..........................................................................19

SUMMARY THAT CAN BE PUBLISHED IN THE FEDERAL REGISTER......34

ANY ADDITIONAL INFORMATION, VIEWS, OR ARGUMENTS AVAILABLE

TO SUPPORT Ryan Wells, DBA OK Real Estate Photography’S REQUEST.........34

CONCLUSION.......................................................................................36

APPENDICES........................................................................................38
GLOSSARY OF ABBREVIATIONS

AGL - Above Ground Level

AOI - Area of Interest

ATC - Air Traffic Control

ATO - Air Traffic Organization

AV - Aerial Vehicle

CFR - Code of Federal Regulations

COA - Certificate of Authorization

FAA - Federal Aviation Administration

FAR - Federal Aviation Regulation

GCS - Ground Control Station

GPS - Global Positioning System

LOL - Loss of Link

NAS - National Airspace System

NOTAM - Notice to Airman

PIC - Pilot In Command

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

333

SO - Safety Observer

SOP - Standard Operating Procedures

UA - Unmanned Aircraft

UAS - Unmanned Aircraft System

VFR - Visual Flight Rules

VLOS - Visual Line of Site

VMC - Visual Meteorological Conditions

VTOL - Vertical Takeoff and Landing
SUMMARY

Ryan Wells, DBA OK Real Estate Photography seeks exemption from the 

requirements of 14 C.F.R §§ 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 

91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b), to operate an Unmanned 

Aircraft System pursuant to Section 333 of the FAA Modernization and Reform Act of 

2012 (FMRA). This exemption will permit Ryan Wells, DBA OK Real Estate 

Photography to operate an Unmanned Aircraft System (UAS) for the commercial 

purpose of conducting aerial video and photography of construction sites, real estate, 

and landscape over certain areas of the United States.

INTRODUCTION AND INTERESTS OF THE PETITIONER

Ryan Wells, DBA OK Real Estate Photography provides its clients with expertise 

and knowledge in advanced technologies and solutions to increase efficiency, 

productivity and effectiveness. Ryan Wells has over 8 years of professional experience 

in Information Technology. He has over 2 years recreational/hobby experience in all 

aspects of aerial video and photography.

The objective of Ryan Wells, DBA OK Real Estate Photography’s aerial video and 

photography operations is to provide

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

targeting:

• Real Estate Photography

• Real Estate Video

• Motion Picture Filming

• Aerial acquisitions used for inspections of public and private structures.

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

• Search and Rescue operations
BACKGROUND

Unmanned Aircraft System: DJI Inspire 1 UAS

Ryan Wells, DBA OK Real Estate Photography seeks an exemption to operate 

DJI systems for compensation or hire within the NAS. The DJI Inspire 1 is 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 1UA is equipped with four main rotors; driven by Lithium Polymer battery 

powered electric motors.

The DJI Inspire 1 UA that will be operated by Ryan Wells, DBA OK Real Estate 

Photography 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, Ryan Wells, DBA OK Real Estate Photography, pursuant to the 

provisions of the Federal Aviation Regulations (14 C.F.R. § 11.61) and the FAA 

Modernization and Reform Act of 2012 (FMRA), Section 333, Special Rules for Certain 

Unmanned Aircraft Systems, hereby petitions the Administrator to commercially operate 

the DJI Inspire 1

UAS in the National Airspace System (NAS), and for an exemption from the 

requirements of 14 C.F.R §§ 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 

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

In consideration of the speed, weight, size, and limited operating area associated

with the unmanned aircraft and its operation, Ryan Wells, DBA OK Real Estate 

Photography’s operation of DJI Inspire 1 UAS meets the conditions of FMRA Section 

333 and therefore, will not require an airworthiness certificate in accordance with 14 

C.F.R. Part 21, Subpart H.
Accordingly, Ryan Wells, DBA OK Real Estate Photography 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.

Ryan Wells, DBA OK Real Estate Photography submits that the requested relief 

is proper since an equivalent level of safety will be ensured. Ryan Wells, DBA OK Real 

Estate Photography 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, Ryan Wells, DBA OK Real Estate Photography will document and 

maintain all maintenance records for 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 Ryan Wells, DBA OK 

Real Estate Photography to the extent necessary to allow a Pilot in Command (PIC) 

holding a private pilot or higher level certificate, as well as an airman medical certificate, 

and who has demonstrated, by meeting minimum flight- hour and currency 

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

consistent with this exemption, including evasive and emergency maneuvers and 

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

Ryan Wells, DBA OK Real Estate Photography seeks relief from Section 91.7(a), 

entitled Civil aircraft airworthiness, because DJI Inspire 1 UAS do not require an 

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

Wells submits that he will ensure that the DJI Inspire 1 UAS is in an airworthy condition, 

prior to every flight, by determining that the UAS is in compliance with the operating 

documents (i.e., Monthly Maintenance Log, and DJI Inspire 1 Instruction Manual), and 

that the aircraft is in a condition for safe flight.

Ryan Wells, DBA OK Real Estate Photography also seeks an exemption from the 

requirements of Section 91.121, entitled Altimeter Settings, as the DJI Inspire 1 UAS

will not have a typical barometric altimeter onboard. However, altitude information of the
DJI Inspire 1UAS 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 Ryan Wells, DBA OK Real Estate Photography’s operation 

of the DJI Inspire 1 UAS within visual line of sight, at or below 500 feet AGL, will ensure 

a level of safety equivalent to Section 91.121.

Additionally, Ryan Wells, DBA OK Real Estate Photography seeks an exemption 

from the requirements of Section 91.151(b), entitled Fuel requirements for flight in VFR 

conditions. Ryan Wells submits that safety will not be affected by operation of the DJI 

Inspire 1 UAS during daylight hours in visual meteorological conditions (VMC)

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

approximately 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, Ryan Wells, DBA OK Real Estate 

Photography provides the following information in support of its petition for exemption:

A. Name And Address Of The Petitioner.

The name and address of the Petitioner and point of contact is:

Ryan Wells, DBA OK Real Estate Photography

8501 Curtis Terrace

Oklahoma City, OK

Tel: (405) 664-7885 

Email: wellsry@gmail.com

B. The Specific Sections Of 14 C.F.R. From Which Ryan Wells, DBA OK Real 

Estate Photography Seeks Exemption.

1. Ryan Wells, DBA OK Real Estate Photography Seeks Exemption From The 

Requirements Of Section 61.113(a) And (b).

Section 61.113, entitled Private pilot privileges and limitations: Pilot in command,

subsections (a) and (b) prescribe the following, in relevant part:

(a) No person who holds a private pilot certificate may act as a pilot in command
(PIC) of an aircraft that is carrying passengers or property for compensation or

hire; nor may that person, for compensation or hire, act as PIC of an aircraft.

(b) A private pilot may, for compensation or hire, act as PIC of an aircraft in connection

with any business or employment if—

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

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

2. Ryan Wells, DBA OK Real Estate Photography Seeks Exemption From The 

Requirements Of Section 91.7(a).

Section 91.7, entitled Civil aircraft airworthiness, subsection (a), states the following:

(a) No person may operate a civil aircraft unless it is in an airworthy condition.

3. Ryan Wells, DBA OK Real Estate Photography Seeks Exemption From The 

Requirements Of Section 91.121.

Section 91.121, entitled Altimeter settings, subsection (a), states the following, in

part:

(a) Each person operating an aircraft shall maintain the cruising altitude or flight

level of that aircraft, as the case may be, by reference to an altimeter that is set,

when operating--

(1) Below 18,000 feet MSL, to--

(i) The current reported altimeter setting of a station along the route and

within 100 nautical miles of the aircraft;

(ii) If there is no station within the area prescribed in paragraph (a)(1)(i) of

this section, the current reported altimeter setting of an appropriate

available station; or

(iii) In the case of an aircraft not equipped with a radio, the elevation of the

departure airport or an appropriate altimeter setting available before departure.

4. Ryan Wells, DBA OK Real Estate Photography Seeks Exemption From The 

Requirements Of Section 91.151(b).

Section 91.151, entitled Fuel requirements for flight in VFR conditions, subsection
(b), states the following:

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

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

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

that for at least 20 minutes.

5. Ryan Wells, DBA OK Real Estate Photography Seeks Exemption From The 

Requirement Of Section 91.405(a).

Section 91.405, entitled Maintenance required, subsection (a), states the following:

Each owner or operator of an aircraft—

(a) Shall have that aircraft inspected as prescribed in subpart E of this part and shall

between required inspections, except as provided in paragraph (c) of this section,

have discrepancies repaired as prescribed in part 43 of this chapter[.]

6. Ryan Wells, DBA OK Real Estate Photography Seeks Exemption From The 

Requirements Of Section 91.407(a)(1)

Section 91.407, entitled Operation after maintenance, preventive maintenance, 

rebuilding, or alteration, subsection (a)(1), states the following:

(a) No person may operate any aircraft that has undergone maintenance, preventive

maintenance, rebuilding, or alteration unless--

(1) It has been approved for return to service by a person authorized under §

43.7 of this chapter[.]

7. Ryan Wells, DBA OK Real Estate Photography Seeks Exemption From The 

Requirements Of Sections 91.409(a)(1) And 91.409(a)(2).

Section 91.409, entitled Inspections, subsection (a), states the following:

(a) Except as provided in paragraph (c) of this section, no person may operate an

aircraft unless, within the preceding 12 calendar months, it has had --

(1) An annual inspection in accordance with part 43 of this chapter and has
been approved for return to service by a person authorized by § 43.7 of this

chapter; or

(2) An inspection for the issuance of an airworthiness certificate in accordance

with part 21 of this chapter.

8. Ryan Wells, DBA OK Real Estate Photography Seeks Exemption From The 

Requirements Of Sections 91.417(a) And 91.417(b).

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

following:

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

registered

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

in paragraph (b) of this section:

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

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

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

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

include--

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

work performed; and

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

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

for return to service.

(2) Records containing the following information:

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

each rotor.

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

rotor, and appliance.

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

are required to be overhauled on a specified time basis.
(iv) The current inspection status of the aircraft, including the time since the

last inspection required by the inspection program under which the aircraft

and its appliances are maintained.

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

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

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

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

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

alteration to the airframe and currently installed engines, rotors,

propellers, and appliances.

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

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

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

work is performed.

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

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

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

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

approved for return to service.

C. The Extent Of Relief Ryan Wells, DBA OK Real Estate Photography Seeks An 

The Reason Ryan Wells Seeks The Relief.

1. Extent Of Relief Ryan Wells, DBA OK Real Estate Photography Seeks And 

The Reason Ryan Wells Seeks Relief From Section 61.113(a) And (b).

Relief from Section 61.113(a) and (b) entitled Private pilot privileges and 

limitations: Pilot in command, is requested to the extent necessary to allow a PIC 

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

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

conduct the proposed UAS flight operations for compensation or hire.

This relief is requested since the limitations set forth in Section 61.113(a) and (b)
state that a private pilot may, for compensation or hire, act as PIC of an aircraft in 

connection with any business or employment if: (1) The flight is only incidental to that 

business or employment; and (2) The aircraft does not carry passengers or property for 

compensation or hire.

As set forth more fully below, Ryan Wells, DBA OK Real Estate Photography 

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 either the 

DJI Inspire 1 UAS in a manner consistent with the operations specifications

as described in this exemption, including evasive and emergency maneuvers, as well

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

Further, Ryan Wells, DBA OK Real Estate Photography 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 Ryan Wells, DBA OK Real Estate Photography’s business; and (2) 

will not carry passengers or property for compensation or hire.

2. Extent Of Relief Ryan Wells, DBA OK Real Estate Photography Seeks And The 

Reason Ryan Wells 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 Ryan Wells, DBA OK Real Estate Photography to determine 

that the DJI Inspire 1 UAS is in airworthy condition prior to every flight by ensuring that 

the UAS is in compliance with the operating documents (i.e., the Ryan Wells, DBA OK 

Real Estate Photography Aerial Operations Manual, Monthly Maintenance Log, and DJI 

Inspire 1 Instruction Manual).

Ryan Wells, DBA OK Real Estate Photography seeks the requested relief 

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

with 14 C.F.R. Part 21, Subpart H. Therefore, Ryan Wells, DBA OK Real Estate 

Photography 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.
3. Extent Of Relief Ryan Wells, DBA OK Real Estate Photography Seeks And The 

Reason Ryan Wells 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), Ryan Wells seeks the requested 

relief because the DJI Inspire 1 UAS’s altimeter may be set on the ground to zero feet 

AGL, rather than the local barometric pressure or field altitude, before each flight.

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

91.121 is sought to the extent necessary to comply with the applicable conditions and 

limitations stated below. As more fully set forth herein, an equivalent level of safety will 

be maintained since the DJI Inspire 1 UAS is equipped with a barometric pressure 

sensor and GPS equipment, which automatically ensures that a ground level pressure 

setting will be established prior to each flight, and provides the PIC with altitude

information of the UA on the heads-up display of the GCS.

4. Extent Of Relief Ryan Wells, DBA OK Real Estate Photography Seeks And The 

Reason Ryan Wells Seeks Relief From Section 91.151(b).

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

conditions, is requested to the extent required to allow flights of the battery powered DJI 

Inspire 1 UAS during daylight hours in visual meteorological conditions

(VMC), under visual flight rules (VFR), for 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. Ryan Wells, DBA OK Real Estate Photography seeks the 

requested relief because without an exemption from Section 91.151(b), the flight time 

duration of the battery powered DJI Inspire 1 UAS will severely constrain the practicality 

of any aerial video or still photo flight operations that Ryan Wells, DBA OK Real Estate 

Photography 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 Ryan Wells, DBA OK Real Estate 

Photography’s proposed operating limitations, ensure that Ryan Wells will safely 

operate the battery powered DJI Inspire 1 UAS during daylight hours in visual 

meteorological conditions (VMC), under visual flight rules (VFR), with enough battery 

power to fly for a total duration of 13.5 minutes to the first point of intended landing and, 

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

5. Extent Of Relief Ryan Wells, DBA OK Real Estate Photography Seeks And The 

Reason Ryan Wells 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, Ryan Wells, DBA OK Real 

Estate Photography requests relief from these Sections because the DJI Inspire 1 UASs 

do not require airworthiness certificates. As set forth more fully below, DJI Inspire 1 UAS 

meet the conditions of FMRA Section 333 for operation without an airworthiness 

certificate. Accordingly, Ryan Wells, DBA OK Real Estate Photography 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., the Ryan Wells, DBA OK Real Estate Photography Aerial Operations 

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

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

UAS.

D. The Reasons Why Granting Ryan Wells, DBA OK Real Estate Photography’s 

Request Would Be In The Public Interest; That Is, How It Would Benefit The Public 

As A Whole.

Granting the present Petition will further the public interest by allowing Ryan 

Wells to safely, efficiently, and economically perform aerial video and photography of

construction sites, real estate, and landscape over certain areas of the United States.
Additionally, use of the DJI Inspire 1 UAS will decrease congestion of the NAS, 

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

of Ryan Wells, DBA OK Real Estate Photography’s proposed operation of the DJI 

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

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

The DJI Inspire 1 UAS is 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

UASs, 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 1 UAS produce 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 UAS, while reducing 

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

are propelled by battery powered electric motors, rather than an

internal combustion engine.

By using the DJI Inspire 1 UASs 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. Aside from the lack of flight crew members located onboard the aircraft, the 

DJI Inspire 1 UAS (weighing approximately 6 pounds 7.5 ounces at its maximum gross 

weight with length of 17.3 inches, 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 

UASs Will Benefit The Economy.

In addition to being safe and efficient, the DJI Inspire 1 UAS are 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 

Ryan Wells, DBA OK Real Estate Photography, 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 UASs, companies such as Ryan Wells, DBA OK 

Real Estate Photography, 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 UASs, provides a stable workforce that 

increases consumer spending; improves local, state, and federal tax revenues; and 

allows companies to invest in research and development in order to remain competitive 

both in the United States and abroad.

4. There Are No Privacy Issues.

Similar to the manned aerial acquisition flight operations that have been 

conducted for decades, Ryan Wells, DBA OK Real Estate Photography’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., 

the Ryan Wells, DBA OK Real Estate Photography Aerial Operations Manual, 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.

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 Ryan Wells, DBA OK Real Estate Photography 

Seeks Exemption.

1. Reasons Why The DJI Inspire 1 UAS Meet 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, Ryan Wells, DBA OK Real Estate 

Photography’s operation of the DJI Inspire 1 UASs meet the conditions of FMRA 

Section 333, and will not require an airworthiness certificate in accordance with 14 

C.F.R. Part 21, Subpart H.
Section 333 provides authority for a UAS to operate without airworthiness 

certification and sets forth requirements for considering whether a UAS will create a 

hazard to users of the NAS or the public, or otherwise pose a threat to national security. 

Specifically, FMRA Section 333 states the following, in part:

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

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

Transportation shall determine if certain unmanned aircraft systems may operate

safely in the national airspace system before completion of the plan and

rulemaking required by section 332 of this Act or the guidance required by section

334 of this Act.

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

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

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

size, weight, speed, operational capability, proximity to airports and

populated areas, and operation within visual line of sight do not create

a hazard to users of the national airspace system or the public or pose a

threat to national security; and

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

certification under section 44704 of title 49, United States Code,

is required for the operation of unmanned aircraft systems identified

under paragraph (1).

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

that certain unmanned aircraft systems may operate safely in the national

airspace system, the Secretary shall establish requirements for the safe operation

of such aircraft systems in the national airspace system.

In seeking this exemption, Ryan Wells, DBA OK Real Estate Photography 

submits that the DJI Inspire 1 UASs 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

UASs Demonstrate Its Safe Characteristics.

The DJI Inspire 1 UAS do 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 Inspire1 UASs.

The technical specifications of the DJI Inspire 1 UAS

are set forth by the DJI Inspire 1 Specifications and Data

Sheet, attached hereto as Exhibit A.

ii. The DJI Inspire 1 UASs Autonomous

Flight And Navigation Modes Enable The UASs To Remain Within A

Defined Operational Area. The DJI Inspire 1 UASs 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 UASs is provided at pages 45-50 of the DJI Inspire 1 User

Manual, attached hereto as Exhibit B.

iii. The DJI Inspire 1 UAS is Designed

For Automatic Return To Home Point Or Hover In The Event Of

Loss Of The Control Link Or Navigation.

When the Control Link is lost, the DJI Inspire 1 UAS will remain stationary, in 

flight, for 3 seconds or more. If, after 3 seconds, the DJI Inspire 1 UAS does not 

reacquire control link data from the GCS, the UAS will assume that the Control Link is 

lost and the UAS will return to the home position (i.e., failsafe mode) via GPS, and will 

descend to the takeoff position and shutdown.

A complete description of the Failsafe Functions of the DJI Inspire 1 at pages 13 

through 15 of the DJI Inspire 1 User Manual, attached hereto as Exhibit B.
iv. The DJI Inspire 1 GCS And Its Operation.

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

GCS and flight control software is provided at pages 40 through 47 of the DJI Inspire 1 

User Manual. DJI Inspire 1 User Manual is attached hereto

as Exhibits B.

b. Flight Operations Of DJI Inspire 1 UAS is

Limited To The Line Of Sight Of A Certificated Pilot in Command With A Safety 

Observer.

Ryan Wells, DBA OK Real Estate Photography will only utilize certificated pilots 

who possess a current and valid airman medical certificate 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 DJI Inspire 1 UASs Will Be Conducted

Pursuant To Specific Operating Limitations.

In seeking this exemption, Ryan Wells, DBA OK Real Estate Photography 

proposes to commercially operate DJI Inspire 1 UAS for the special purpose of 

conducting aerial video and photography over certain areas of United States, pursuant 

to the following specific operating limitations:

1. Operations authorized by this grant of exemption will be limited to the following

aircraft described in the operating documents, rotorcraft 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 500 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.

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

permitted.

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

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

The SO and PIC must be able to communicate verbally at all times. Electronic

messaging or texting is not permitted during flight operations. The PIC must be

designated before the flight and cannot transfer his or her designation for the 

duration

of the flight. The PIC must ensure that the SO can perform the functions

prescribed in the operating documents.

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

and avoiding other air traffic and other ground based obstacles/obstructions and

is not permitted to operate the camera or other instruments.

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

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

discrepancy

exists between the conditions and limitations contained in the grant of

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

and limitations contained in the grant of exemption take precedence and

must be followed. Otherwise, the operator must follow the procedures as outlined

in its operating documents. The operator may update or revise its operating

documents. It is the operator’s responsibility to track such revisions and present

updated and revised documents to the Administrator upon request. The operator

must also present updated and revised documents if it petitions for extension or

amendment to the grant of exemption. If the operator determines that any update

or revision would affect the basis upon which the FAA granted the exemption,
then the operator must petition for amendment to its grant of exemption. The

FAA’s UAS Integration Office (AFS-80) may be contacted if questions arise 

regarding

updates or revisions to the operating documents.

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

condition

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

of the UAS, the aircraft is prohibited from operating until the necessary

maintenance has been performed and the UAS is found to be in a condition for

safe flight. The Ground Control Station must be included in the preflight inspection.

All maintenance and alterations must be properly documented in the

aircraft records.

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

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

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

test flight must make an entry in the aircraft records.

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

inoperable

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

sections of the operating documents.

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

maintenance,

overhaul, replacement, inspection, and life limit requirements.

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

requirements, in accordance with the operating documents. Maintenance, 

inspection,

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 UASs operated under this exemption must comply with all manufacturer

Safety Bulletins.

16. The authorized person must make an entry in the aircraft record of the corrective

action taken against discrepancies discovered between inspections.

17. The PIC must possess at least a private pilot certificate and at least a current

third- class 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 experiencebuilding flights, all persons not essential for flight operations are considered

nonparticipants, and the PIC must operate the UA with appropriate distance

from nonparticipants in accordance with 14 C.F.R. § 91.119.

19. UAS operations may not be conducted during night, as defined in 14 C.F.R. §

1.1. All operations must be conducted under visual meteorological conditions

(VMC). If flight at night is required, a special request will be made at the FAA

office closest to proposed area of operations. Flights under special visual flight

rules (SVFR) are not authorized.

20. The UA may not operate within 5 nautical miles of an airport reference point as

denoted on a current FAA-published aeronautical chart unless a letter of agreement

with that airport’s management is obtained, and the operation is conducted

in accordance with a NOTAM as required by the operator’s COA. The letter of

agreement with the airport management must be made available to the Administrator

upon request.
21. The UA may not be operated less than 500 feet below or less than 2,000 feet

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

PIC.

22. If the UA loses communications or loses its GPS signal, it must return to a 

predetermined location within the planned operating area and land or be recovered

in accordance with the operating documents.

23. The PIC must abort the flight in the event of unpredicted obstacles or 

emergencies

in accordance with the operating documents.

24. The PIC is prohibited from beginning a flight unless (considering wind and

forecast weather conditions) there is enough power to fly at normal cruising

speed to the intended landing point and land the UA with 25% battery power

remaining.

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

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

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

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

hours prior to the operation. All operations shall be conducted in accordance

with airspace requirements in the ATO issued COA including class of airspace,

altitude level and potential transponder requirements.

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

serial number, registered in accordance with 14 C.F.R. part 47, and have 

identification

(N- Number) markings in accordance with 14 C.F.R. part 45, Subpart

C. Markings must be as large as practicable.

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

and control of the UA must comply with the Federal Communications Commission

(FCC) or other appropriate government oversight agency requirements.

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

to the PIC at the Ground Control Station of the UAS any time the UAS is
operating. These documents must be made available to the Administrator or any

law enforcement official upon request.

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

operations and activities at all times.

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

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

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

vessels, vehicles, and structures unless:

a. Barriers or structures are present that sufficiently protect nonparticipating

persons from the UA and/or debris in the event of an accident. The operator

must ensure that nonparticipating persons remain under such protection.

If a situation arises where nonparticipating persons leave such protection

and are within 500 feet of the UA, flight operations must cease

immediately and/or;

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

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

and the PIC has made a safety assessment of the risk of operating

closer to those objects and determined that it does not present an undue

hazard, and;

c. Operations nearer to the PIC, SO, operator trainees or essential persons

do not present an undue hazard to those persons per § 91.119(a).

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

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

Permission from land owner/controller or authorized representative will be obtained

for each flight to be conducted.

33. Any incident, accident, or flight operation that transgresses the lateral or vertical

boundaries of the operational area as defined by the applicable COA must

be reported to the FAA's UAS Integration Office (AFS-80) within 24 hours.

Accidents must be reported to the National Transportation Safety Board

(NTSB) per instructions contained on the NTSB Web site: www.ntsb.gov.
2. Reasons Why An Exemption From The Requirements Of Section 61.113(a)

And (b) Would Not Adversely Affect Safety.

Ryan Wells, DBA OK Real Estate Photography 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 Ryan Wells, DBA OK Real Estate Photography’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, Ryan Wells, DBA OK Real Estate Photography submits that the 

additional manned airmanship experience of a commercially certificated pilot would not 

correlate to the airmanship skills necessary for Ryan Wells, DBA OK Real Estate 

Photography’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).

Ryan Wells, DBA OK Real Estate Photography will not allow any PIC to operate 

the DJI Inspire 1 UAS unless that PIC has demonstrated, by meeting minimum flighthour requirements or the DJI Inspire 1 UAS training and currency requirements, that the 

PIC is able to safely operate the DJI Inspire 1 UAS in a manner consistent with this 

exemption, including evasive and emergency maneuvers and maintaining appropriate 

distances from people, vessels, vehicles and structures.

Specifically, the PIC must have accumulated and logged, in a manner consistent

with 14 C.F.R. § 61.51(b), 25 hours of total time as a UAS rotorcraft pilot (with a 

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

of UAS to be used for operations under the exemption). In addition to the hour 
requirements, the PIC must accomplish 3 takeoffs and landings in the preceding 90 

days (for currency purposes).

As in Exemption Nos. 11062, 11138, and 11153, prior documented flight 

experience that was obtained in compliance with applicable regulations will ensure an 

equivalent level of safety during Ryan Wells, DBA OK Real Estate Photography’s 

proposed operations. The Administrator has held that prior documented flight 

experience that was obtained in compliance with applicable regulations would ensure 

safe operations, stating as follows:

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

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

accumulated and logged, in a manner consistent with 14 CFR 61.51(b), 25 hours of

total time as a UAS rotorcraft pilot including at least 10 hours logged as a UAS pilot

with a multi-rotor UAS. Prior to operations under Exemption No. 11062, the

PIC must also have accumulated and logged a minimum of 5 hours as a UAS pilot

operating the same make and model of UAS to be used for operations under the

exemption. For clarification, the FAA considers these minimum hour requirements

to be inclusive rather than additive; i.e. 5 hours make and model time may be 

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

total 25 hours of UAS rotorcraft time. In addition to the hour requirements, the PIC

must accomplish 3 takeoffs and landings in the preceding 90 days (for currency

purposes). The FAA finds that at a minimum, the flight-hour requirements in 

Exemption No. 11062 are appropriate to practice and build proficiency in the skills

necessary to safely conduct the petitioner’s proposed operations. The FAA also

finds that prior documented flight experience that was obtained in compliance with

applicable regulations would satisfy this requirement. Training, proficiency, and

experience-building flights can also be conducted under the grant of exemption to

accomplish the required flight time. During training, proficiency, and experience 

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

accordance with 14 C.F.R 91.119.
Exemption No. 11138 at page 15.

Accordingly, Ryan Wells, DBA OK Real Estate Photography will ensure safe 

operations by not allowing any PIC to operate the DJI Inspire 1 UAS unless that PIC 

has demonstrated, by meeting minimum flight-hour and currency requirements, that the 

PIC is able to safely operate the DJI Inspire 1 UAS in a manner consistent

with the exemption, including evasive and emergency maneuvers and maintaining 

appropriate distances from people, vessels, vehicles and structures.

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

Would Not Adversely Affect Safety.

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

because prior to every flight, Ryan Wells, DBA OK Real Estate Photography will ensure 

that the DJI Inspire 1 UAS is in an airworthy condition based upon the UAS’s 

compliance with its operating documents and as stated in the conditions and limitations 

herein.

Additionally, the FAA has previously granted relief from Section 91.7(a) specific to

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

Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 

11112, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161).

4. Reasons Why An Exemption From The Requirements Of Section 91.121

Would Not Adversely Affect Safety.

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

because the altitude information of the DJI Inspire 1 UAS will be

provided to the PIC via GPS equipment 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 Ryan Wells, DBA OK Real Estate 

Photography’s operation of the DJI Inspire 1 UAS within visual line of sight, at or below 

500 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 UASs at 

ground level.
The FAA has previously granted relief from Section 91.121 specific to UAS, in 

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

Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11112, 

11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161).

5. Reasons Why An Exemption From The Requirements Of Section 91.151(b)

Would Not Adversely Affect Safety.

A grant of this exemption would ensure an equivalent level of safety established 

by 14 C.F.R. Section 91.151(b) as a result of (1) the technical specifications of the DJI 

Inspire 1 UASs; (2) the limitations on the proposed flight operations; and (3) the location 

of the proposed flight operations. Accordingly, Ryan Wells will ensure that it will safely 

operate the battery powered DJI Inspire 1 UAS during daylight hours in VFR conditions, 

with enough battery power to fly for a total duration of 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; the limitations on the proposed flight operations; and the location of the proposed 

operations, will ensure an equivalent level of safety established by 14 C.F.R. Section 

91.151(b). Furthermore, safety will be ensured as the DJI Inspire 1 UAS provide audible 

and visual warnings to the PIC at the GCS when the UAS experiences low battery 

voltage, the first warning occurring at approximately 33% remaining battery power, and 

again at approximately 10% remaining battery power.

At the critically low battery level, the DJI Inspire 1 UAS will descend and land 

automatically.

Significantly, previous exemptions granted by the FAA concerning Section 91.151

establish that safety is not adversely affected when the technical characteristics and 

operating limitations of the UAS are considered. Relief has been granted for manned 

aircraft to operate at less than the minimums prescribed in Section 91.151, including 

Exemption Nos. 2689, 5745, and 10650. Moreover, the FAA has previously granted 

relief from Section 91.151 specific to UAS, in circumstances similar, in all material 

respects, to those presented herein (e.g. Exemption Nos. 8811, 10808, 10673, 11042, 
11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11136, 11138, 11150, 

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

6. Reasons Why An Exemption From The Requirements Of Sections

91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), And 91.417(a) & (b) Would

Not Adversely Affect Safety.

In seeking this exemption, Ryan Wells, DBA OK Real Estate Photography 

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 Ryan Wells, DBA OK Real Estate 

Photography will use trained technicians to perform maintenance, alterations, or 

preventive maintenance on the UASs using the methods, techniques, and practices

prescribed in the operating documents (i.e., the Ryan Wells, DBA OK Real Estate 

Photography Aerial Operations Manual, Monthly Maintenance Log, and DJI Inspire 1 

Instruction Manual). Furthermore, Ryan Wells, DBA OK Real Estate Photography will 

document and maintain all maintenance records for the DJI Inspire 1 UAS.

Since the DJI Inspire 1 UASs will be inspected as prescribed

by the operating documents, Ryan Wells, DBA OK Real Estate Photography 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 Manuals are attached hereto as 

Exhibit B; a copy of the DJI Inspire 1 UAS Maintenance LOG is

attached hereto as Exhibit C.

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

Wells will use trained technicians to perform maintenance, alterations or preventive

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

the operating documents.

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

established by Sections 91.407, 91.417(a) and 91.417(b), because all maintenance of 

the DJI Inspire 1 UAS will be performed by trained technicians.

Maintenance will be documented and maintained utilizing the monthly maintenance log.

Significantly, previous exemptions granted by the FAA concerning Sections
91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) establish that safety 

is not adversely affected when the technical characteristics and operating limitations of 

the UAS are considered.

In consideration of Ryan Wells, DBA OK Real Estate Photography’s proposed 

operating limitations, the operating documents, and the technical aspects of the DJI 

Inspire 1 UAS, Ryan Wells, DBA OK Real Estate Photography submits that safety will 

not be adversely affected by granting exemption from 14 C.F.R. Sections 91.405(a), 

91.407(a)(1) and (a)(2), 91.409(a)(2), and 91.417(a) and (b). The FAA has previously 

granted relief specific to UAS in circumstances similar, in all material respects, to those 

presented herein (e.g. Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 

11080, 11109, 11110, 11112, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 

11160, 11161).

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

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

2012 (FMRA) and 14 C.F.R. § 21.16 entitled Special Conditions, Ryan Wells, DBA OK 

Real Estate Photography requests that the FAA prescribe special conditions for the 

intended operation of the DJI Inspire 1 UASs, which contain such safety standards that 

the Administrator finds necessary to establish a level of safety equivalent to that 

established by 14 C.F.R. Part 21, Subpart H, and 14 C.F.R §§ 61.113(a) & (b), 91.7 (a), 

91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b). 

Such special conditions will permit safe operation of the UAS for the limited purpose of 

conducting aerial video and photography over certain areas of the United States for 

compensation or hire.

FMRA Section 333 sets forth the requirements for considering whether a UAS will 

create a hazard to users of the NAS or the public, or otherwise pose a threat to national 

security; and further, provides the authority for such UAS to operate without 

airworthiness certification in accordance with any requirements that must be established 

for the safe operation of the UAS in the NAS.

Likewise, the Administrator may prescribe special conditions pursuant to 14 

C.F.R. § 21.16, for operation of the DJI Inspire 1 UASs, since the airworthiness 
regulations of 14 C.F.R. Part 21 do not contain adequate or appropriate safety 

standards, due to the novel or unusual design features of the aircraft. Section 21.16, 

entitled Special Conditions, states the following:

If the FAA finds that the airworthiness regulations of this subchapter do not contain 

adequate or appropriate safety standards for an aircraft, aircraft engine, or propeller 

because of a novel or unusual design feature of the aircraft, aircraft engine or 

propeller, he prescribes special conditions and amendments thereto for the product.

The special conditions are issued in accordance with Part 11 of this chapter and

contain such safety standards for the aircraft, aircraft engine or propeller as the

FAA finds necessary to establish a level of safety equivalent to that established in

the regulations.

See 14 C.F.R. § 21.16.

Therefore, in accordance with FMRA Section 333 and 14 C.F.R. § 21.16, the FAA

may prescribe special conditions for Leading Edge’s intended operation of the DJI 

Inspire 1 UAS, which contain such safety standards that the Administrator

finds necessary to establish a level of safety equivalent to that established by 14

C.F.R. Part 21, Subpart H, and 14 C.F.R Sections 61.113(a) & (b), 91.7(a), 91.121,

91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b).

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

From Which Ryan Wells, DBA OK Real Estate Photography Seeks Exemption:

Ryan Wells, DBA OK Real Estate Photography seeks exemption from the 

requirements of 14 C.F.R Sections 61.113(a)&(b), 91.7(a), 91.121, 91.151(b), 

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

A Brief Description Of The Nature Of The Exemption Ryan Wells, DBA OK Real 

Estate Photography Seeks:

This exemption will permit Ryan Wells, DBA OK Real Estate Photography to 

commercially operate an Unmanned

Aircraft System (UAS) for the purpose of conducting aerial video and photography

over certain areas of the United States.
G.Any Additional Information, Views, Or Arguments Available To Support Ryan 

Wells’s Request.

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

(FMRA) Section 333, which directs the Secretary of Transportation to determine if 

certain UAS may operate safely in the NAS. As such, Ryan Wells, DBA OK Real Estate 

Photography’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, Ryan Wells, DBA OK Real Estate Photography will 

operate the DJI Inspire 1 UAS safely in the NAS, without creating a hazard to users of

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

CONCLUSION

As set forth herein, Ryan Wells, DBA OK Real Estate Photography 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 UASs 

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 Ryan Wells, DBA OK Real Estate Photography to safely, efficiently, and 

economically operate the DJI Inspire 1 UASs commercially within the NAS.

WHEREFORE, in accordance with the Federal Aviation Regulations and the FAA

Modernization and Reform Act of 2012, Section 333, Ryan Wells, DBA OK Real Estate 

Photography respectfully requests that the Administrator grant this Petition for an 

exemption from the requirements of 14 C.F.R Sections 61.113(a) & (b), 91.7(a), 91.121, 

91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b), and 
permit Ryan Wells, DBA OK Real Estate Photography to operate the DJI Inspire 1 UAS 

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

areas of the United States.

Dated: June 24, 2015

Respectfully submitted,

Ryan Wells, DBA OK Real Estate Photography

/s/ Ryan Wells

Ryan Wells, DBA OK Real Estate Photography

8501 Curtis Terrace

Oklahoma City, OK 73132

Email: wellsry@gmail.com
Appendices:

A – DJI Inspire 1 Specifications Data Sheet

B – DJI Inspire 1 Manufacturer’s User Manual

C – Monthly Maintenance Log
APPENDIX – A

DJI INSPIRE 1 TECHNICAL SPECIFICATIONS

Ryan Wells, DBA OK Real Estate Photography 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 information 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) – 6lbs 7.5291oz (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 – 10m/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 – 140F to 1040F (-100C to

400C)

2.2.1.15 Dimensions – 17 .” x 17 .” x 12”

2.2.2 Gimbal

2.2.2.1 Model – ZENMUSE X3

2.2.2.2 Output Power (with camera) – Static: 9W; In Motion: 11W

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

2.2.2.4 Angular Vibration Range - ±0.030

2.2.2.5 Mounting – Detachable

2.2.2.6 Controllable Range – Pitch: -900 to +300; Pan: ±3200

2.2.2.7 Mechanical Range – Pitch: -1250 to 450; Pan: ±3300

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 – 4000x3000
2.2.3.6 ISO Range – 100-3200

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

2.2.3.10 Operating Temperature Range - 320F - 1040F (00C - 400C)

2.2.4 Transmitter

2.2.4.1 Name – C1

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 (-100C to 400C)

2.2.4.6 Battery – 600mAh LiPo 2S

APPENDIX – B

DJI Inspire 1 Manufacturer’s User Manual

(Separate Document labeled APPENDIX – B

DJI Inspire 1 Manufacturer’s User Manual)

APPENDIX – C

(Separate Document labeled APPENDIX – C - Monthly Maintenance Log)