UNITED STATES OF AMERICA DEPARTMENT OF TRANSPORTATION FEDERAL AVIATION ADMINISTRATION

WASHINGTON, DC

Regulatory Docket No. _______________

IN THE MATTER OF THE PETITION FOR EXEMPTION OF:

Eugene T. Marable Jr. 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 A 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 September 11 , 2015
Eugene T. Marable Jr. 540 Red Fox Rd Camden, SC 29020 Tel: ( 803) 606

- 2972 FAA Cert ificate: 37462342 TABLE OF CONTENTS
Page

GLOSSARY OF ABBREVIATIONS...................................................................................3

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

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

BACKGROUND................................................................................................................... .4

BASIS FOR PETITI ON.........................................................................................................5

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

THE SPECIFIC SECTIONS OF 14 C.F.R. FROM WHICH EUGENE T. MARABLE JR. SEEKS EXEMPTION........

..... .... ....... ................................... ..................................................8

THE EXTENT OF RELIEF EUGENE T. MARABLE JR. SEEKS AND THE REASON EUGENE T. MARABLE JR. SEEKS THE RELIEF........

... ............................................................ . ....... ..............11

THE REASONS WHY GRANTING EUGENE T. MARABLE JR. ’S REQUEST WOULD BE IN THE PUBLIC INTEREST .........................................................15

THE REASONS WHY GRANTING THE EXEMPTION WOULD NOT ADVERSELY AFFEC T SAFETY..........................................................................19

SUMMARY THAT CAN BE PUBLISHED IN THE FEDERAL REGISTER......34
ANY ADDITIONAL INFORMATION, VIEWS, OR ARGUMENTS AVAILABLE TO SUPPORT EUGENE T. MARABLE JR. ’S REQUEST...

... ............... ......................................................... ... ......34

CONCLUSION................................................................................................................... .35

APPENDICES.......................................................................................

. .373 GLOSSARY OF ABBREVIATIONS

AGL Above Grou nd 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 Regulatio n 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 Landing4 SUMMARY
Eugene T. Marable Jr. 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
Eugene T. Marable Jr. to operate an Unmanned Aircraft System (UAS) for the commercial
purpose of conducting aerial video and photography of construction sites, real estate,
private eve nts, search and rescue, and flight training.

INTRODUCTION AND INTERESTS OF THE PETITIONER
Eugene T. Marable Jr. provides his clients with expertise and knowledge i n advanced
technologies and sol utions to increase efficiency, productivity and effectiveness

. Eugene T.

Marable Jr. also provides his clients with the highest quality digital content for use in their
commercial, personal, and non

- profit multimedia projects. Eugene T. Marable Jr. has 1
years of professional experience in video production and photo graphy. Eugene T. Marable

Jr. holds a FAA Commercial Rotary Wing airman certificate and has over 20 years and
3,400 hours of Military rotary wing flight experience . The objective of Eugene T. Marable

Jr. ’s aerial video and photography operations is to prov ide high quality imaging for a
variety of wedding, commercial, public, and residential uses, specifically targeting

 Wedding Videography and Photography

 Motion Picture Filming and Commercial Cinematography

 Real Estate Photography5  Increase public knowledge o f UAS and promote safe UAS operations.

BACKGROUND
Unmanned Aircraft System : DJI INSPIRE 1
Eugene T. Marable Jr. seeks an exemption to operate DJI systems for compensation

or hire within the NAS. The DJI Inspire 1 is a vertical takeoff and landing (VTOL)
Unmanned Aircraft (UA) with a Ground Control Station (GCS) utilizing electronic tablet
or smart phone systems. The DJI Inspire 1 has a maximum gross weight of approximately
2 pounds 11 ounces, while having a length of 1 6 inches width of 16 inches, height of 8
inches, and a maximum speed of approximately 29 knots. The DJI Inspire 1 is equipped
with four main rotors; driven by Lithium Polymer battery powered electric motors.

The DJI Inspire 1 that will be operated by Euge ne T. Marable Jr. 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, Eugene T. Marable Jr. , 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 §§6

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, Eugene T. Marable Jr. ’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, Eugene T. Marable Jr. requests relief from Sections 91.405(a),
91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b), as these se ctions set forth
requirements for maintenance that only apply to aircraft with an airworthiness certificate.
Eugene T. Marable Jr. submits that the requested relief is proper since an
equivalent level of safety will be ensured. Eugene T. Marable Jr. will use experienced
personnel or technicians to perform maintenance, alterations, or pr eventive 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, Eugene T. Marable Jr. will document and maintain all maintenance records

for the DJI Inspire 1 UAS

. Relief from certain requirements of Section 61.113(a) and (b), entitled Private pilot
privileges and limitations: Pilot i n command , is requested by Eugene T. Marable Jr. 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

- h our 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 and7

emergency maneuvers and maintaining appropriate distances from people, vessels,

vehicles and struc tures. Eugene T. Marable Jr. seeks relief from Section 91.7(a), entitled Civil aircraft

airworthiness , because the DJI Inspire 1 UAS do not require an airworthiness certificate in
accordance with 14 C.F.R. Part 21, Subpart H. As such, Eugene T. Marable Jr

. submits that

he will ensure that the DJI Inspire 1 UAS are in an airworthy condition, prior to every
flight, by determining that the UASs are in compliance with the operating documents (i.e.,
Monthly Maintenance Log, and DJI Inspire 1 Instruction Manual), and that the aircraft are
in a condition for safe flight.
Eugene T. Marable Jr. 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 1 UAS will
be provided to the PIC via Global Positioning System (GPS) equipment and radio
communications telemetry data link, which downlinks from the U A to the GCS for active
monitoring of the flight path. This altitude information, combined with Eugene T. Marable

Jr. ’s operation of the DJI Inspire 1 UAS within visual line of sight, at or below 4 00 feet
AGL, will ensure a level of safety equivalent to Se ction 91.121.
Additionally, Eugene T. Marable Jr. seeks an exemption from the requirements of
Section 91.151(b), entitled Fuel requirements for flight in VFR conditions

. Eugene T.

Marable Jr. submits that safety will not be affected by operation of the DJ I 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 minutes8

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, Eugene T. Marable Jr. provides the
following information in support of its petition for exemption:

A. Name And Address Of The Petitioner.

The name and addr ess of the Petitioner and point of contact is:
Eugene T. Marable Jr. 540 Red Fox Rd Camden, SC 29020 Tel: (803) 606

- 2972 Email: tmarab1@icloud.com FAA Certificate: 3746234
B. The Spec ific Sections O f 14 C.F.R. From Which Eugene T. Marable Jr. Seeks Exemption.

1. Eugene T. Marable Jr. 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 pri vate 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. Eugene T. Marable Jr. Seeks Exemption From The Requirements Of Section 91.7(a).9 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. Eugene T. Marable Jr. 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. Eugene T. Marable Jr. Seeks Exemption From The Requirements Of Section 91.151(b).

S ection 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. Eugene T. Marable Jr. Seeks Exemption From The Requirement Of Section 91.405(a).10 Section 91.405, entitled Maintenance required , subsection (a), states the following:
Each owner or operator of an aircraft

— (a) Shall have that aircra ft 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. Eugene T. Marable Jr. Seeks Exempt ion 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. Eugene T. Marable J r. 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 unl ess, 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 iss uance of an airworthiness certificate in accordance with part 21 of this chapter.

8. Eugene T. Marable Jr. Seeks Exemption From The Requirements Of Sections 91.417(a) And 91.417(b).
Section 91.417, entitled Maintenance records , subsections (a) and (b), s tate 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:11 (1) Records of the maintenance, prev entive 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 t he 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, fo r 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 ch apter 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.12 (2) The records specified in paragraph (a)(2) of this section shall be retain ed 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 Eugene T. Marable Jr. Seeks And The Reason Eugene T. Marable Jr. Seeks The Relief.

1. Extent Of Relief Eugene T. Marable Jr. Seeks And The Reason Eugene T. Marable Jr. Seeks Relief From Section 61.113(a) And (b).

Rel ief 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

c ertificate, 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 p ilot 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, Eugene T. Marable Jr. 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.13 Further, Eugene T. Marable Jr. submits that all flights of the DJI Inspire 1 UAS , conducted by the PIC pursuant to the grant of th is Petition: (1) will be incidental to Eugene

T. Marable Jr. ’s business; and (2) will not carry passengers or property for compensation

or hire.

2. Extent Of Relief Eugene T. Marable Jr. Seeks And The Reason Eugene T.

Marable Jr. 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 Eugene T. Marable Jr. to determine that the DJI Inspire 1 UAS are in airworthy condition prior to every fl ight by ensuring that the UAS is in compliance with
the operating documents (i.e., the Eugene T. Marable Jr. Aerial Operations Manual,
Monthly Maintenance Log, and DJI Inspire 1 Instruction Manual).
Eugene T. Marable Jr. 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, Eugene T. Marable Jr. will ensure that the DJI Inspire 1 UAS are in airworthy
condition based upon its compliance with the operat ing documents (i.e ., Monthly
Maintenance Log, and 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 Eugene T. Marable Jr. Seeks And The Reason Eugene T. Marable Jr. 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 traffic14

control (ATC) in feet above ground level (AGL), Eugene T. Marable Jr. seeks the
requested relief because the DJI Inspire 1 UAS altimeter may be set on the ground to zero
feet AGL, rather than the local barometric pressure or field altitude, be fore 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 1UAS are 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 Eugene T. Marable Jr. Seeks And The Reason Eugene T. Marable Jr. 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 minut es to the first point of intended
landing and, assuming normal cruising speed, to fly after that for at least 4.5 minutes.
Eugene T. Marable Jr. 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
Eugene T. Marable Jr. proposes to conduct pursuant to this Petition.
Significantly, as set forth below, the technical spe cifications of the DJI Inspire 1

UAS , the DJI Inspire 1 operating documents, and Eugene T. Marable Jr. ’s proposed
operating limitations, ensure that Eugene T. Marable Jr. will safely operate the battery15

powered DJI Inspire 1 UAS during daylight hours in vi sual 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 minu tes.

5. Extent Of Relief Eugene T. Marable Jr. Seeks And The Reason Eugene T. Marable Jr. 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, Eugene T. Marable Jr. requests

relief from these Sections because the DJI Inspire 1 UAS do not require airworthiness
certificates. As set forth more fully below, the DJI Inspire 1 UAS meet the conditions of
FMRA Section 333 for operation without an airworthiness certificate. Accordingly,
Eugene T. Marable Jr. will use trained technicians to perform maintenance, alterations, or

pr eventive maintenance on the UAS using the m ethods, techniques, and practices
prescribed in the UAS operating documents (i.e., the Eugene T. Marable Jr. Aerial
Operations Manual, Monthly Maintenance Log, and DJI Inspire 1 Instruction Manual).
Furthermore, Eugene T. Marable Jr. will document and main tain all maintenance records

for the DJI Inspire 1 UAS

. D. The Reasons Why Granting Eugene T. Marable Jr. ’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 Eugene T.

Marable Jr. to safely, efficiently, and economically perform aerial video and photography
of construction sites, real estate, and landscape over certain areas of the Unite d 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 of16

Eugene T. Marable Jr. ’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 are battery powered and serve as a safe, efficient, and

economical alternative to the manned aircraft traditi onally 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 Phantom 3 Professional or DJI Phantom 2 Vision Plus

UAS would reduce the amount of manned airc raft 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 a nd departing aircraft will be reduced. The

DJI Inspire 1 UAS do not require an airport to takeoff or land. Likewise, a reduction of
manned aircraft conducting aerial video and photography missions would result in fewer
aircraft that must be handled by air traffic control during the ground, takeoff, departure,
arrival, and landing phases of flight operations.
2. The Public Will Benefit From The Safety And Efficiency Of The DJI Inspire 1 UAS.
Conducting aerial acquisitions with the DJI Inspire 1 UAS , instea d 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 approximat ely 20

- 30 gallons per hour of leaded aviation17

fuel. The DJI Inspire 1 UAS , while reducing the carbon footprint of aerial acquisitions,

also elimin ates noise pollution, as the UAS are propelled by battery powered electric
motors, rather than an internal com bustion engine.
By using the DJI Inspire 1 UAS to perform aerial acquisitions, the substantial risk
to life and property in the air and on the ground, which is usually associated with
traditional manned aircraft flight operations, will be substantially re duced or completely
eliminated. Aside from the lack of flight crew members located onboard the aircraft, the

DJI Inspire 1 UAS (weighing approximately 2 pounds 11 ounces and 6 pounds 7.5 ounces
respectively, at their maximum gross weights with lengths of 1 6 inches and 17.3 inches
respectively, widths of 16 inches and 17.7 inches respectively, and with no fuel on board),
has less physical potential for collateral damage to life and property on the ground, and in
the air, compared to the manned aircraft that typically conduct similar operations
(weighing approximately 6,000 pounds with a wingspan of approximately 42 feet, a length
of 34 feet, and a fuel capacity of 180 gallons).
3. Performing Aerial Video and Photography Operations With The DJI Inspire 1 UAS Will Benefit The Economy.
In addition to being safe and efficient, the DJI Inspire 1 UAS is also an economical
alternative to using manned aircraft to conduct similar aerial operations. As such, operation

of the DJI Inspire 1 UAS will allow United States based individuals , like Eugene T.

Marable Jr. , 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 acti ons 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 only18

allows companies greater operational flexibility compared to manned aircraft, but provides
such flexibility without the high operational cost of a traditional manned aircraft.
By operating the DJI Inspire 1 UAS , Individuals such as Eugene T. Marable Jr. , can remain competitive a nd profitable, and therefore, provide greater job stability to
employees and contractors, which will ultimately contribute to growth of the U.S.
economy. Improved financial performance of U.S. companies, through commercial use of

the DJI Inspire 1 UAS , pro vides 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 Pri vacy Issues.
Similar to the manned aerial acquisition flight operations that have been conducted for
decades, Eugene T. Marable Jr. ’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 Eugene T. Marable Jr. Aerial Operations
Manual, Monthly Maintenance Log, and DJI Inspire 1 Instruction Manual) which requires
property owner involvement as well as local law enforceme nt 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 Eugene T. Marable Jr. 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, Eugene T. Marable Jr. ’s operat ion of the DJI19

Inspire 1 UAS 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.
Speci fically, 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 certa in 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 Syste ms.

-- 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 populate d 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 airworthines s 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 cert ain 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, Eugene T. Marable Jr. submits that the DJI Inspire 1

UAS can operate safely in the NAS pursuant to FMRA Section 333, as demonstrated by:
(a) the characteristics of the DJI Inspire 1 UAS ; (b) the pilot certification requirement; and
(c) the specific operating limitations.20 a. T he Specifications Of The DJI Inspire 1 UAS Demonstrate Its Safe Characteristics.

The DJI Inspire 1 UAS do es not create a hazard to users of the NAS or the public,
or otherwise pose a threat to national security considering its size, weight, speed, and
operational capability.

i. Technical Specifications Of The DJI Inspire 1 UAS

. The technical specifications o f the DJI Inspire 1 UAS are set forth by the DJI
Inspire 1 Specifications and Data Sheet, attached hereto as Appendix A.

ii. The DJI Inspire 1 UAS Autonomous Flight And Navigation Modes Enable The UAS To Remain Within A Defined Operational Area.

The DJI Inspire 1 UAS may be operated in both manual and fully autonomous
flight modes. A complete description of the flight and navigational modes of the DJI
Inspire 1 UAS is provided at pages 25

- 35 of the DJI Inspire User Manual , attached hereto

as Appendix B.

iii. The DJI Inspire 1 UAS Are 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 UAA will remain stationary, in
flight, for 3 seconds or more. If, after 3 seconds, the DJI Inspire 1 UAS do 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., fail safe mode) via GPS, and will descend to the
takeoff position and shutdown.
A complete description of the Failsafe Functions of the DJI Inspire 1 UAS are set
forth at pages 27 through 29 of the DJI Inspire 1 User Manual , attached hereto as Appendix

B

. iv. The DJI Inspire 1 GCS And Its Operation.21 A complete description of the operation and specifications of the DJI Inspire 1 GCS
and flight control software is provided at pages 32 through 43 of the User Manual

. DJI
Inspire 1 User Manual are attached hereto as Appendix s B

.

b. Flight Operations Of DJI Inspire 1 UAS Are Limited To The Line Of Sight Of A Certificated Pilot in Command With A Safety Observer. Eugene T. Marable Jr. 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 Ins pire 1 UAS Will Be Conducted Pursuant To Specific Operating Limitations. In seeking this exemption, Eugene T. Marable Jr. proposes to commercially operate

DJI Inspire 1 UAS for the special purpose of conducting aerial video and photography over

certain a reas 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 opera ting documents, rotorcraft UAS 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 S must be operated at an altitude of no more than 4 00 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 r equires 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.22 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/obstruction s 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 co nditions 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 follo w 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 UA S 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 ins pection 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, mainte nance, overhaul, replacement, inspection, and life limit requirements.23 14. The operator must carry out its maintenance, inspections, and record keeping requirements, in accordance with the operating documents. Maintenance, inspection, alterations, and st atus 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 t his 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 ma nner 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, prof iciency, and experience

- building 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.24 22. If the UA loses communications or loses its GPS signal, it must return to a pr e

determined 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 document s. 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 m ore 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 requirem ents. 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 require ments. 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 suf ficiently 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 such25 protectio n 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 h as 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 wil l 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 Off ice (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 Requiremen ts Of Section 61.113(a) And (b) Would Not Adversely Affect Safety. Eugene T. Marable Jr. 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 U AS 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 Eugene T. Marable Jr. ’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 Phantom 3 Professional or DJI

Phantom 2 Vision Plus UAS, Eugene T. Marable Jr. submits that the additional manned26

airmansh ip experience of a commercially certificated pilot would not correlate to the
airmanship skills necessary for Eugene T. Marable Jr. ’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).
Eugene T. Marable Jr

. will not allow any PIC to operate the DJI Phantom 3

Professional or DJI Phantom 2 Vision Plus UAS unless that PIC has demonstrated, by
meeting minimum flight

- hour requirements or the DJI Phantom 3 Professional or DJI

Phantom 2 Vision Plus UAS training an d currency requirements, that the PIC is able to
safely operate the DJI Phantom 3 Professional or DJI Phantom 2 Vision Plus 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

expe rience that was obtained in compliance with applicable regulations will ensure an
equivalent level of safety during Eugene T. Marable Jr. ’s proposed operations. The27

Administrator has held that prior documented flight experience that was obtained in
complia nce 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 accum ulated 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 preced ing 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, Eugene T . Marable Jr. will ensure safe operations by not allowing any
PIC to operate the DJI Phantom 3 Professional or DJI Phantom 2 Vision Plus UAS unless
that PIC has demonstrated, by meeting minimum flight

- hour and currency requirements,

that the PIC is able to safely operate the DJI Phantom 3 Professional or DJI Phantom 2

Vision Plus UAS in a manner consistent with the exemption, including evasive and
emergency maneuvers and maintaining appropriate distances from people, vessels,

vehicles and structures.

3. Re asons Why An Exemption From The Requirements Of Section 91.7(a) Would Not Adversely Affect Safety.28 The equivalent level of safety established by Section 91.7(a) will be maintained
because prior to every flight, Eugene T. Marable Jr. will ensure that the DJI Phantom 3

Professional or DJI Phantom 2 Vision Plus 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 reli ef 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, 1115 8, 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 I nspire 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 Eugene T. Mara ble Jr. ’s operation of the DJI Inspire 1 UAS
within visual line of sight, at or below 4 00 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. Prio r to each flight, a zero altitude initiation point

is autom atically established by the UAS at ground level.
The FAA has previously granted relief from Section 91.121 specific to UAS, in
circumstances similar, in all material respects, to those presented h erein (e.g. Exemption
Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11112, 11136, 11138,
11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161).29 5. Reasons Why An Exemption From The Requirements Of Section 91.151(b) Would Not Adversely Aff ect Safety. A grant of this exemption would ensure an equivalent level of safety established by
14 C.F.R. Section 91.151(b) as a result of (1) the technical specifications of the DJI Inspire

1 UAS ; (2) the limitations on the proposed flight operations; a nd (3) the location of the
proposed flight operations. Accordingly, Eugene T. Marable Jr. 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 N o. 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). Furthermo re, 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 w hen 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, to30

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, Eugene T. Marable Jr. 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) w ill be

met because Eugene T. Marable Jr. 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 Eugene T. Marable Jr. Aerial
Operations Manual, Monthly Maintenance Log, and DJI Inspire 1 Instruction Manual).
Furthermore, Eugene T. Marable Jr. will document and maintain all maintenance records

for the DJI Inspire 1 UAS

. Since the DJI Inspire 1 UAS will be inspected a s prescribed by the operating
documents, Eugene T. Marable Jr. will maintain the equivalent level of safety established
by Sections 91.405(a), 91.409(a)(1), and 91.409(a)(2). A copy of the DJI Inspire 1 User

Manual is attached hereto as Appendix B ; a copy of the DJI Inspire 1 UAS Maintenance

LOG is attached hereto as Appendix C

. Likewise, the exemption sought will not adversely affect safety because Eugene T.

Marable Jr. will use trained technicians to perform maintenance, alterations or preventiv e maintenance on the UAS using the methods, techniques, and practices prescribed by the
operating documents.31 Furthermore, the exemption sought would maintain an equivalent level of safety
established by Sections 91.407, 91.417(a) and 91.417(b), because al l 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), 91.4 07(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 Eugene T. Marable Jr. ’s proposed operating lim itations, the
operating documents, and the technical aspects of the DJI Inspire 1 UAS , Eugene T.

Marable Jr. 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, 111 38, 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 Co nditions , Eugene T. Marable Jr.
requests that the FAA prescribe special conditions for the intended operation of the DJI
Inspire 1 UAS , which contain such safety standards that the Administrator finds necessary
to establish a level of safety equivalent to that established by 14 C.F.R. Part 21, Subpart H,
and 14 C.F.R §§ 61.113(a) & (b), 91.7 (a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1),32

91.409(a)(1) & (a)(2), and 91.417(a) & (b). Such special conditions will permit safe
operation of the U AS for the limit ed 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 ot herwise pose a threat to national security; and further, provides the
authority for such UAS to operate without airworthiness certification in accordance with
any requirements that must be established for the safe operation of the UAS in the NAS.

Likewise , the Administrator may prescribe special conditions pursuant to 14 C.F.R.
§ 21.16, for operation of the DJI Inspire 1 UAS , since the airworthiness regulations of 14
C.F.R. Part 21 do not contain adequate or appropriate safety standards, due to the novel o r 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, ai rcraft 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

est ablish 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).33

F. A Summary That Can Be Publishe d In The Federal Register, stating: The Rules From Which Eugene T. Marable Jr. Seeks Exemption:
Eugene T. Marable Jr. 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 Eugene T. Marable Jr. Seeks:
This exemption will permit Eugene T. Marable Jr. 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 Eugene T. Marable Jr. ’s Re quest. 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, Eugene T. Marable Jr. ’s request f or 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 othe rwise pose a threat to national
security; and further, provides the authority for such UAS to operate without airworthiness

certification.
As discussed in detail above, Eugene T. Marable Jr. 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, Eugene T. Marable Jr. seeks an exemption pursuant to 14
C.F.R. § 11.61 and Section 333 of th e FAA Modernization and Reform Act of 201234

(FMRA), which will permit safe operation of the DJI Inspire 1 UAS commercially, without
an airworthiness certificate, for the limited purpose of conducting aerial video and
photography over certain areas of the Un ited 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 Eugene

T. Marable Jr. to safely, effic iently, and economically operate the DJI Inspire 1 UAS
commercially within the NAS.

WHEREFORE , in accordance with the Federal Aviation Regulations and the FAA
Modernization and Reform Act of 2012, Section 333, Eugene T. Marable Jr. respectfully

requests t hat 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 him to operate the DJI Inspir e 1

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

certain areas of the United States.

Date d: September 11 , 2015

Respectfully submitted,

_________________________ Appendic es : Eugene T. Marable Jr. 540 Red Fox Rd A

– DJI Inspire 1 Specifications Camden, SC 29020 B

– DJI Inspire 1 User Manual Tel: (803) 606

- 2972 C

– Monthly Maintenance Log35 APPENDIX

– A

DJI INSPIRE 1 PROFESSIONAL TECHNICAL SPECIFICATIONS
Eugene T. Marable Jr. 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 c an also be set to limit flight to no higher than a predetermined and set altitude as well as limit f l ight 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)

MODEL : T600
WEIGHT (BATTERY INCLUDED) : 2935 g
HOVERING ACCURACY (G PS MODE) : Vertical: 0.5 m/ Horizontal: 2.5 m

MAX ANGULAR VELOCITY : Pitch: 300°/s/ Yaw: 150°/s

MAX TILT ANGLE : 35°

MAX ASCENT SPEED : 5 m/s

MAX DESCENT SPEED : 4 m/s

MAX SPEED : 22 m/s (ATTI mode, no wind)

MAX FLIGHT ALTITUDE : 4500 m

MAX WIND SPEED RESIS TANCE : 10 m/s

MAX FLIGHT TIME : Approximately 18 minutes

MOTOR MODEL : DJI 3510

PROPELLER MODEL : DJI 1345

INDOOR HOVERING : Enabled by default

OPERATING TEMPERATUR E RANGE :

- 10° to 40° C

DIAGONAL DISTANCE : 559 to 581 mm

DIMENSIONS : 438x451x301 mm

POWER SPECTRAL DENSI TY : 9.06mW/MHz36 A PPENDIX

– B

DJI Phantom 3 Professional Manufacturer’s User Manual37 APPENDIX

– C
DJI Inspire 1 Maintenance Log38