Michael Mercado

MercadoVisualz

747 W. Pasadena Ave

Mountain House, Ca 95391

I. Regulations from which Exemption is Requested

Relief is requested from the following FAR’s:

A. 14 CFR Part 21, Subpart H: Airworthiness Certificates and 14 CFR

91.203(a) (1)

B. 14 CFR 61.56: Flight Review

C.14 CFR 61.113 (a) & (b): Private pilot privileges and limitations

D. 14 CF R 91.119: Minimum safe altitudes

E. 14 CFR 91.121: Altimeter settings

F. 14 CFR 91.151 (a): Fuel requirements for flight in VFR conditions

G. 14 CFR 91.405 (a):Maintenance required; 91.407 (a) (1): Operation after

maintenance, preventive maintenance, rebuilding, or alteration; 91.409 (a)

(2): Inspections; 91.417 (a) & (b): Maintenance records

A. 14 CFR Part 21; Subpart H: Airworthiness Certificates and 14 CFR 

91.203(a)(1)

MercadoVisualz requests exemption from attaining airworthiness certificates required

by 14 CFR 91.203(a)(1). Section 333 of the Reform Act allows the FAA to exempt

aircraft from the requirement of an airworthiness certificate in consideration of the size,

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

the UAS.

Equivalent of Safety

The DJI Inspire 1 weighs 6.4 lbs to include payload, no persons on board, and no

flammable fuels. The operational location can be preloaded using GPS way points to

include route altitude and speed. The DJI Inspire 1 also has a return to home button

which safely brings the drone back to its starting point. The PIC and VO will do a

thorough preflight to determine the airworthiness of the Inspire 1 prior to each flight on
location. The safety guidelines will be followed from the Inspire 1 User Manual, Flight

Operations Manual, and preflight checklist.

B. 14 CFR 61.56: Flight Review

MercadoVisualz requests exemption from 14 CFR 61.56 which requires the PIC to

conduct a flight review consisting of a minimum of 1 hour of flight training and 1 hour of

ground training. This requirement is not pertinent to the safe operations of the Inspire 1.

Equivalent of Safety

The equivalent level of safety will be achieved by following the procedures of the

manufacturer in the Inspire 1 User Manual and Flight Operations manual. Maintaining

currency and proficiency are a top priority for MercadoVisualz. Bi-monthly flights

will be the minimum requirement for operation of the Inspire 1. These flights, if not for

business purposes will consist of at least 18 minutes (battery life limit) of flight time with

Inspire 1, and 10 manual (no GPS) take off and landings.

C. 14 CFR 61.113: Private pilot privileges and limitations: Pilot in Command

MercadoVisualz requests exemption from 14 CFR 61.113(a) which states that Except

as provided in paragraphs (b) through (h) of this section, no person who holds a private

pilot certificate may act as pilot in command of an aircraft that is carrying passengers or

property for compensation or hire; nor may that person, for compensation or hire, act as

pilot in command of an aircraft.

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

in connection with any business or employment if:

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

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

The UAS will only carry a camera onboard for hire. No living thing at anytime will be

carried, therefor an exemption from the above requirement is requested.

Equivalent of Safety

While being used for commercial and private use, the UAS will never carry live people,

animals, or creatures, and therefore has a much lower operational safety requirement

than a passenger craft.

D. 14 CFR 91.119(c): Minimum safe altitudes
MercadoVisualz request exemption from 14 CFR 91.119(c), which states that except

when necessary for takeoff or landing, no person may operate an aircraft below the

following altitudes:

(a) Anywhere. An altitude allowing, if a power unit fails, an emergency landing without

undue hazard to persons or property on the surface.

(b) Over congested areas. Over any congested area of a city, town, or settlement, or

over any open air assembly of persons, an altitude of 1,000 feet above the highest

obstacle within a horizontal radius of 2,000 feet of the aircraft.

(c) Over other than congested areas. An altitude of 500 feet above the surface, except

over open water or sparsely populated areas. In those cases, the aircraft may not be

operated closer than 500 feet to any person, vessel, vehicle, or structure.

Equivalent of Safety

Due to the small size, weight, limited speed and absence of flammable liquids on board,

the Inspire 1 is safer than an airplane. Flying will only occur with the proper consent of

the property owners and/or local officials. This permission will give ample time for all

owners and neighbors to be aware of the times of operation. Multiple signs will be

posted to ensure people are aware when drone operations are being conducted. At no

time will the UAS be operated at or near any airport, exceed 400ft AGL, and or be flown

over any person, vessel, vehicle or structure without prior coordination and permission

of the concerned parties (i.e. base operations, FBO, marina operations manager, etc.).

E. 14 CFR 91.121: altimeter setting

MercadoVisualz requests exemption from 14 CFR 91.121 which states that:

(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.

The UAS needs an exemption because there is not a configurable barometric altimeter

on board.

Equivalent of Safety

Precise altitude control is accomplished easily by two methods. The first is done by 

preloading

the precise GPS waypoints for the intended route of flight, to include altitude
and airspeed. The second is done while operating in a manual flight mode by inputing a

maximum allowable altitude into the flight control system on the controller. This limit

prevents the Inspire 1 from ever exceeding that altitude. At no time will this limit exceed

400ft AGL in either pre-planned or manual mode. The Inspire 1 will also remain within

visual line of sight at all times.

F. 14 CFR 91.151(a): Fuel requirements for flight in VFR conditions

MercadoVisualz requests exemption from 14 CFR 91.151(a), which states that: (a) No

person may begin a flight in an airplane 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—

(1) During the day, to fly after that for at least 30 minutes; or

(2) At night, to fly after that for at least 45 minutes.

The Inspire 1 uses an 18 minute battery therefore cannot meet the criteria for this

requirement.

Equivalent of Safety

Planning all flights to land after 15 minutes or 25% battery power remaining, whichever

comes first, would provide equal safety conditions. The Inspire 1 has a safety feature

which automatically returns it directly to the point of origin or planned destination,

whichever is closer, upon reaching 25% battery power remaining. This prevents power

loss in flight. Additionally if the remote controller is low on batteries the pilot can

manually command the Inspire 1 to return to the point of origin with the push of a button.

This prevents any case where airborne control of the drone may be lost due to a dead

remote control. This function can be activated at distances greater than visual range,

however Vertical Vantage will only operate the UAS in visual line of sight and day VFR

conditions.

G. 14 CFR 91.405(a) Maintenance required;91.407(a)(1) Operation after

maintenance, preventative maintenance, rebuilding, or alteration; 91.409(a)

Inspections; 91.417(a)&(b) Maintenance records

MercadoVisualz request exemption from maintenance and inspection requirements

from 14 CFR 91.405(a), 91.407(a)(1), 91.409(a), and 91.417(a)&(b). An exemption is

required for aircraft holding an airworthiness certificate. Presuming an approval for

waiver of 14 CFR Part 21, subpart H and 14 CFR 91.203(a)(1) the Inspire 1 will not

require an airworthiness certificate. The Inspire 1 does not hold this certificate.

Equivalent of Safety

Ensuring the UAS is operational before a flight is key to maintaing an excellent safety
record. Keeping a log book for all maintenance preformed and any maintenance test

flights will be recorded. This will ensure proper user maintenance is conducted on time.

All maintenance will be in accordance with the DJI user manual.

II. Public Interest

This exemption is in the public’s interest because it offers a more cost effective, more

efficient way of supporting their needs with increased safety. The use of a lightweight

UAS offers the general public something only successful companies could afford; views

from the sky. These aerial views can benefit small and large businesses alike.

The Inspire 1 is a safer alternative than other methods like hiring a helicopter or

airplane. A UAS can go to places those aircraft cannot and also eliminates the human

risk factor. For example, someone wanting to make a short real-estate clip of their

property no longer needs to hire a helicopter which is not very cost effective or as safe.

Also, for the purpose of inspecting infrastructure, trenches, agriculture, property lines

etc. The UAS provides an annoyance free solution while decreasing the volume of

aircraft in the National Airspace above 400 ft AGL. Additionally, the newest DJI UAS,

the Inspire 1 incorporates increased safety measures such as push-button return home

capability, low battery sensing which activates automatic return, more efficient low

impact blades, and increased telemetry allowing greater control by the pilot.

Small drones can have the job done in a more timely manner with less manpower. This

is much safer alternative will not only mitigate unnecessary risk but provide the public 

an affordable and dependable service. Because of this it is in my opinion that Vertical

Vantage working with the Inspire1 would be in the greatest interest of the public.

III. Privacy

All flights will have signed permission/consent forms from the property owner. Ample

time will be given to notify neighbors and signs will be placed in plain sight when the

Inspire 1 is aerial. These flights will only occur in predetermined and controlled

locations which will protect peoples privacy. Prior permission from the city, county,

state or federal officials will be requested if flights need to occur over public

lands/property.

IV. 14 CFR Summary
I, Michael Mercado, MercadoVisualz., request exemption from the following rules to

commercially operate the Inspire 1 in National Airspace for Aerial photography,

videography, inspection/survey and real estate services.

14 CFR Part 21, Subpart H: Airworthiness Certificates and 14 CFR

91.203(a) (1)

14 CFR 61.56: Flight Review

14 CFR 61.113 (a) & (b): Private pilot privileges and limitations

14 CF R 91.119: Minimum safe altitudes

14 CFR 91.121: Altimeter settings

14 CFR 91.151 (a): Fuel requirements for flight in VFR conditions

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

maintenance, preventive maintenance, rebuilding, or alteration; 91.409 (a)

(2): Inspections; 91.417 (a) & (b): Maintenance records

MercadoVisualz

Michael Mercado, Owner

747 W Pasadena Ave

Mountain House, Ca 95391

Telephone: (209) 740-0855

mercadovisualz@gmail.com