July 31, 2015 

Utah Aerial Imaging LLC 

1046 W Taylors Park Cir. 

Taylorsville, UT 84123 

U.S. Department of Transportation, Docket Operations

West Building Ground Floor, Room W12-140 

1200 New Jersey Avenue, SE 

Washington, DC 20590

Regarding: 

Exemption Request Pursuant To Section 333 of the FAA Reform Act of 2012 and Part 11 of the 

Federal Aviation Regulations. 

Dear Sir or Madam: 

Utah Aerial Imaging LLC, hereby submits to the Federal Aviation Administration, pursuant to the FAA 

Modernization and Reform Act of 2012, an exemption petition, in accordance with Section 333 of the 

Act, to request that Utah Aerial Imaging LLC, be exempted from the Federal Aviation Regulations 

(“FARs”) listed below, in order to operate the Unmanned Aerial Systems (UAS) known as DJI Inspire 1 

commercially in airspace regulated by the Federal Aviation Administration (FAA). 

Purpose for Exemption & Public Interest: 

Recognizing the demand for aerial services both in and outside of the United States, Utah Aerial Imaging 

LLC has been founded with the intention to deliver safe, professional grade aerial videography and 

photography in addition to our other professional services for the purposes of film and video production, 

advertising and marketing. Utah Aerial Imaging LLC provides an array of clients with professional 

videography and photography from ground level as well as professional editing and 3d animation. The 

granting of this exemption request will provide immediate benefit to commercial and residential real 

estate industries, architectural firms, home builders, land developers, travel agencies, resorts, and film 

production companies in need of aerial application both within and outside of the United States. The use 

of UAS in industries such as these provides a more informational and enticing viewpoint, from normally 

unreachable areas, with more efficiency and cost effectiveness than by airplane or helicopter. Each of 

these industries require photo and video in order to advertise or market homes, buildings and large areas 

of land or travel destinations and greatly benefit from a photo and video service that can provide an 
experience encompassing larger areas, not achievable at the ground level. With marketing and advertising 

achieving a higher level of service to potential buyers and clients, there is a resulting increase in business 

that will ultimately help to accelerate the economy as a whole. Countries outside of the United States will 

greatly desire and benefit from the content we provide and are a part of; seeing increased tourist activity 

and advancement of economical growth. The general public will benefit from safe and efficient services 

that are conservative to fuel, time, emissions, noise ect, Utah Aerial Imaging LLC desires to utilize the 

state-of-the-art DJI Inspire1 unmanned aircraft system (UAS) in accordance with laws and regulations 

regarding Unmanned Aircraft System (UAS) operations conducted within the National Airspace System 

(NAS) and in compliance with the Standards of the International Civil Aviation Organization (ICAO).

The name and address of the applicant is: 

Utah Aerial Imaging LLC 

ATTN: Colton J. Sandoval 

1046 W Taylors Park Cir. 

Taylorsville, UT 84123 

Email - colton@utahaerialimaging.com

Phone: 801-879-4494 

List of Specific Sections of 14 CFR for which exemption is sought:

14 CFR 21, Subpart H –Airworthiness Certificates

14 CFR 45.23 (b), Display of marks; general

14 CFR 61.113(a) and (b), Certification: Pilots, Flight Instructors, and Ground Instructors 

14 CFR 91.7 (a), Airworthiness required for operation

14 CFR 91.9 (b) (2), Civil Aircraft flight manual, marking, and placard requirements

14 CFR 91.103 (b) (2), Preflight action 

14 CFR 91.109, Flight instruction 

14 CFR 91.119 (c), Minimum safe altitudes 

14 CFR 91.121, Altimeter settings 

14 CFR 91.151, Fuel requirements for flights in VFR conditions

14 CFR 91.203 (a) and (b),Civil aircraft: Certifications required

14 CFR 91.405 (a), Maintenance required 

14 CFR 91.407 (a) (1), Operation after maintenance 

14 CFR 91.409 (a)(1) (2), Inspections 

14 CFR 91.417 (a) and (b), Maintenance records
Description of Operations: 

Utah Aerial Imaging LLC recognizes the importance of safety in any hobby or commercial application 

and will operate only under controlled conditions in airspace that is 1) Limited 2) Predetermined 3) 

Controlled as to access. All operations shall be conducted over private or controlled-access property with 

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

owner/controller or authorized representative will be obtained for each flight to be conducted. The PIC 

camera operation will always be controlled by a professional cinematographer with access to only camera 

and gimble movement ensuring that the Pilot in Control (PIC) will have a constant visual line-of-sight 

(VLOS) in accordance with the statutory mandate under section 333(b)(1). 

Aircraft Description 

 

DJl lnspire 1- Model T600 is designed as a professional aerial filmmaking and photography platform 

comprised of 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 (2935g) 6 pounds 7.5 ounces, a length of 17.3 inches, width of 17.7 inches, height of 11.8 

inches, a maximum speed of approximately (22m/s) 42 knots and a maximum flight time of 18 minutes. 

The DJI Inspire 1 is equipped with four main rotors; driven by Lithium Polymer battery powered electric 

motors.

The DJI Inspire 1 is equipped with a built-in Flight Control System which includes an integral inertial 

sensor and a barometric altimeter that measure both attitude and altitude. Included is a shielded, anti-static 

compass which reads geomagnetic information and assists in accurately calculating position and 

altitude. GPS mode allows UAS to hover in place when radio controls are released. 

The Flight Control System includes a Failsafe Function. A complete description of the Failsafe Functions 

for the DJI Inspire 1 are found at pages 14 through 16 of Appendix A DJI-Inspire1-User Manual ,attached 

hereto. Failsafe functions are activated if the Remote Control is powered off, the DJI Inspire 1 has flown 

outside effective control range, the signal between the DJI Inspire 1 and the Remote Control is blocked, 

or if there is interference causing a signal problem.When activated, the Failsafe Function automatically 

flies the DJI Inspire 1 at a predetermined altitude, back to the Home Point (the start location) and lands it. 

If GPS mode is not active, Failsafe will execute a controlled descend and automatic landing.Through the 

DJI Inspire 1 Assistant software, each flight operation will be programmed with a maximum radius 
distance and maximum altitude from the Home Point such that the flight control system will limit 

operations to within the confines of the property or closed production set. 

*It is of crucial importance to note that the DJI Inspire 1 has both single and dual remote 

capabilities. Single remote use of the DJI Inspire 1 for aerial filmmaking or photography purposes 

can present issues with flight safety and pilot error while simultaneously operating control of 

aircraft and camera. Utah Aerial Imaging LLC will only operate under a dual remote configuration 

with PIC under full control of Master remote, while a secondary individual operates the movement 

of the camera, ensuring no distractions for pilot error.

Manufacturer’s Documentation:

Detailed manufacturer’s design information and operating limitations (current to this date) are contained 

the in the following manuals in the appendices at the end of this document: 

· Appendix A DJI-Inspire1-User Manual 

· Appendix B Inspire_1_Maintenance_Manual

· Appendix C Inspire_1_Safety_Guidelines

Accordingly, Utah Aerial Imaging LLC requests relief from Sections 91.405(a), 91.407(a)(l), 

91.409(a)(1) & (2), and 9l.417(a) & (b), as these sections set forth requirements for maintenance that 

only apply to aircraft with an airworthiness certificate.

Procedures for Ensuring UAS Is In a Condition Safe for Flight: 

Preflight Checklist: As a minimum, the following items will be checked prior to initiating an UAS 

operation with DJI Inspire 1- 

1. Before Departing For Site 

• Aircraft and Remote Controllers fully charged 

• Tablets fully charged 

• Ensure Firmware is Updated on AC and RC 

• Cache location maps into all DJI Pilot App Devices 

• Check weather - Winds under 23 MPH or 10 mps, visibility for 3 statute miles, Cloud layer above 500’ 

• A Notice to Airmen (NOTAM) has been requested not more than 72 hours in advance and not less than 

48 hours prior to the operation. 

2. Location On-Site Check 

• Operation is during daylight hours ( official sunrise to sunset, local time) 
• Flight path is at least 500 ft. from all non-participating persons, vessels, vehicles and structures unless 

protective barriers or structures are present, or permission is granted, or such operations present no 

hazard to the Pilot in Command, Camera Operator and other essential persons.

• Check flying area free of overhead obstructions including wires, low flying AC, trees, tall buildings 

• Weather meets conditions stated above 

• Confirm flight plan with camera operator 

4. Physical Aircraft Check 

• Desired ND filter attached to camera 

• Camera locked in place 

• SD card in Camera 

• Motors Clear of Foreign Object Debris (FOD) 

• Check propellers for melting, misshapen or cracks 

• Propellers are hand tight 

• Prop locks are firmly attached and quick release plastic base has no cracks or fissures 

5. Remote Controller Check 

• Antennas are oriented properly 

• Switch to P-GPS mode 

• Landing gear switched and oriented down 

• Check battery level of RC for minimum 75% 

6. DJI Pilot APP Check 

• Maximum flight altitude set = 400 Feet 

• Failsafe mode, Set for 10M clearance above lowest obstacle in flight plan 

• RC signal lost set to Return-to-Home 

• Check sensors 

• Gyroscope between “-1.0 to +1.0” 

• Acceleration between “-1.0 to +1.0” 

• Compass MOD between “1400=1599” 

• Check IMU 

• Image Transmission Channel set and stable 

• Battery Cells all 4.28V or greater, at least 98% battery, ensure no greater than .2V between battery cells 

• Ensure enough satellites are locked on 

• Turn other devices on Airplane Mode 

• Face AC into the wind allowing for movement towards operator in case of emergency 

• Check heading of aircraft 

• Ensure home point is accurately set on map 
Proposed Flight Operations: 

No operations will occur within 5 miles of a non-towered airport reference point as denoted on a current 

FAA-published aeronautical chart, unless a letter agreement with the airport’s management is obtained, 

and the operation is conducted in accordance with a Notice to Airman (NOTAM) as required by the 

Certificate of Waiver or Operation (COA).

The DJI Inspire 1 will be utilized for the following: 

1. Aerial videography for public and/or private use including, but not limited to, marketing, tourism 

promotion, residential real estate, commercial real estate, architecture, builders, land developers, resorts, 

golf courses, events, film production and other related professional activities. 

2. Aerial photography for public and/or private use including, but not limited to, marketing, tourism 

promotion, residential real estate, commercial real estate, architecture, builders, land developers, resorts, 

golf courses, events, film production and other related professional activities.

 3. Aerial photography for public and/or private use including but not limited to television, public events 

and other cinematography projects. 

4. Aerial videography for public and/or private use including but not limited to television, public events 

and other cinematography projects.

UAS Weight: Under 55 lbs, approximately (2935g) 6 pounds 7.5 ounces 

Proposed speed: Will typically be slower, between 5-25 MPH for better quality video and photo. 

Altitude: Below 400 ft. Above Ground Level (AGL) provides adequate visual perspective or area and 

structures to be surveyed (flight control systems will be set to limit altitude) 

Flight Time: Each flight will be 15 minutes or less. Flights will be terminated at 25% battery power 

reserve or 30 minutes of flight time whichever occurs first. 

Distances: The unmanned aircraft must remain close enough for the operator to be capable of seeing the 

aircraft with vision unaided by any device. The DJI Inspire 1 will not be operated less than 500 feet below 

or less than 2,000 feet horizontally from a cloud when visibility is less than 3 statute miles from the PIC. 

Operations will be aborted immediately if the PIC encounters unpredicted obstacles or emergencies. Safe 

descent and landing procedures will be followed in accordance with operating documents. 

Area of Operation: Utah Aerial Imaging LLC will primarily operate in the state of Utah, with ability to 

travel to any approved location both in and outside of the United States, in compliance with NAS 

limitations and requirements to operate a UAS around those areas in accordance with all applicable parts 

of 14 CFR including, but not limited to, parts 45, 47, 61, and 91. 

Operating Outside of the United States 
In accordance with Title 14, Chapter I, Subchapter B, Subpart A 11.83 I request relief under this 

exemption for operation outside of the United States in compliance with the Standards of the International 

Civil Aviation Organization (ICAO). Companies who desire services such as these to help promote 

business, gain exposure, raise awareness and increase revenue are not limited to the United States and are 

requested worldwide. Many countries lack the ability or means to replicate these services and require 

outsourcing. Noticeable increases in tourism are linked directly to media exposure of known and 

unknown destinations across the globe. Our intention is to provide professional grade cinematography 

and photography to those requesting services outside of the United States in accordance with local laws 

and regulations. 

Relief Sought From 14 CFR 

14 CFR 21, Subpart H –Airworthiness Certificates

The UAS to be operated carries neither pilot nor passenger and carries no explosive materials or 

flammable liquids. Given the size, weight, speed and limited operating area associated with the aircraft to 

be utilized, I request exception. In the restricted environment and under the conditions proposed operation 

will be at least as safe, or safer, than a conventional aircraft operating with an airworthiness certificate 

without said restrictions.

14 CFR 45.23 (b), Display of marks 

Due to the size of this UAS it does not have a cockpit, cabin, or pilot station on which to market certain 

words or phrases. Lettering would be very difficult to place on such a small aircraft and dimensions 

would need to be smaller than required minimums.

14 CFR 61.113(a) and (b), Certification: Pilots, Flight Instructors, and Ground Instructors

Utah Aerial Imaging can achieve an equivalent level of safety as achieved by current Regulations due to 

inability of proposed UAS to carry pilots or passengers. Further, while helpful, a pilot license will not 

ensure remote control piloting skills. The risks attended to the operation of the UAS in question are far 

less than the risk levels inherent in the commercial activities outlined in 14 CFR 61, et seq. Thus, 

allowing PIC to meet an exceed current safety levels in relation to 14 CFR 61.113 (a) & (b) while 

operating UAS in question. 

14 CFR 91.7 (a), Airworthiness required for operation

As there will be no airworthiness certificate for the aircraft, should this exemption be granted, no FAA 

regulatory standard will exist for determining airworthiness. Given the size of the aircraft for maintenance 

and use of safety check list prior to each flight an equivalent level of safety will be provided.
14 CFR 91.9 (b) (2), Civil Aircraft flight manual, marking, and placard requirements 

Given the size and configuration, the proposed UAS has no ability to carry a flight manual on the aircraft. 

There is no room capacity, or pilot on board to adequately carry flight manual. An equivalent level of 

safety will be maintained by keeping the flight manual at ground control point where the pilot will have 

immediate access to it.

14 CFR 91.103 (b) (2), Preflight action

As FAA approved flight manuals will not be provided for the aircraft an exemption will be needed. As a 

minimum, sections listed above under titled “Preflight Checklist” will be checked prior to initiating an 

UAS operation. An equivalent level of safety will be provided by preflight protocol to properly match the 

machine.

14 CFR 91.109, Flight instruction

UAS and remotely piloted aircraft do not have fully functional dual controls. Flight control is achieved 

through the use of a control box that communicates with the aircraft via radio communications. The 

equivalent level of safety provided because neither a pilot nor passenger will be carried in the aircraft, and 

by the speed and size of the aircraft.

14 CFR 91.119 (c), Minimum safe altitudes

Proposed UAS DJI Inspire 1 will not exceed an altitude of 500 feet AGL and would not comply with this 

requirement. The equivalent level of safety will be achieved given the size, weight, and speed of the UAV 

as well as the location where it is operated. In addition, the low altitude operations of the UAV will ensure 

separation between these small-UAS operations and the operations of conventional aircraft that must 

comply with 14 CFR 91.119.

14 CFR 91.121, Altimeter settings

Proposed UAS's will not have a typical barometric altimeter onboard. However, altitude information of 

the DJI Inspire 1 UAS will be provided to the PIC via Global Positioning System (GPS) equipment and 

radio communications telemetry data link, which downlinks from the UA to the GCS for active 

monitoring of the flight path. This altitude information, combined with the 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, an equivalent level of safety will be maintained since the DJI Inspire 1 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. 
14 CFR 91.151, Fuel requirements for flights in VFR conditions 

Proposed UAS will be operated during daylight hours in visual meteorological conditions (VMC) under 

visual flight rules (VFR). DJI Inspire 1 has a maximum flight time of 18 minutes which allows 5 minutes 

reserve and has a second level of safety that is achieved through the use of an aircraft battery monitoring 

system. The aircraft system will alert the operator of low battery voltage and return the aircraft to its take 

off location before battery capacity is depleted. An equivalent level of safety can be achieved by limiting 

flights to 15 minutes or 15% of battery power whichever happens first. This restriction would be more 

than adequate to return the UAV to its planned landing zone from anywhere in its limited operating area. 

14 CFR 91.203 (a) and (b), Civil aircraft: Certifications required 

Similar to, 14 CFR91.9 (b) (2), given the size and configuration, the UAS has no ability to carry 

certificate and registration documents on the aircraft. An equivalent level of safety will be achieved by 

keeping these documents, to the extent they are applicable to the UAS, at the ground control point where 

pilot has immediate access to them. 

14 CFR 91.405 (a), Maintenance required; 14 CFR 91.407 (a) (1), Operation after maintenance; 14 

CFR 91.409 (a)(1) (2), Inspections; 14 CFR 91.417 (a) and (b), Maintenance records 

Given these sections only apply to aircraft with an airworthiness certificates, theses sections do not apply 

to this applicant. As a safety precaution, operator will perform preflight inspections and ensure UAS is in 

working condition before initiating each flight. DJl lnspire 1 UAS meets the conditions of FMRA Section 

333 for operation without an airworthiness certificate. Accordingly, Utah Aerial Imaging LLC will 

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

and practices prescribed in the UAS operating documents (i.e., Appendix A DJI-Inspire1-User Manual, 

Appendix B Inspire_1_Maintenance_Manual, Appendix C Inspire_1_Safety_Guidelines). 

As discussed in detail above, Utah Aerial Imaging LLC 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. 

Respectfully, 

Colton J. Sandoval, President/Owner 

Utah Aerial Imaging LLC