Regulatory Docket No. : 

 

IN THE MATTER OF THE PETITION FOR EXEMPTION OF: 

JASON MENDEZ 

FOR AN EXEMPTION SEEKING RELIEF FROM THE REQUIREMENTS OF 

 

TITLE 14 OF THE CODE OF FEDERAL REGULATIONS 

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

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

COMMERCIAL OPERATION 

OF DJI Inspire 1 

UNMANNED AIRCRAFT SYSTEMS. 

 

PURSUANT TO SECTION 333 OF 

THE FAA MODERNIZATION AND REFORM ACT OF 2012 

 

(PUBLIC LAW 112-95) 

Submitted on October 19, 2015

JASON MENDEZ

6335 E. Heaton Ave

Fresno, CA 93727

(559) 824-1680

Jason@jason-mendez.com

UNITED STATES OF AMERICA

DEPARTMENT OF

TRANSPORTATION FEDERAL

AVIATION ADMINISTRATION

WASHINGTON, DC
GLOSSARY OF ABBREVIATIONS 

AGL Above Ground Level

AOI Area of Interest

ATC Air Traffic Control

ATO Air Traffic Organization

AV Aerial Vehicle

CFR Code of Federal Regulations

COA Certificate of Authorization

FAA Federal Aviation Administration

FAR Federal Aviation Regulation

GCS Ground Control Station

GPS Global Positioning System

LOL Loss of Link

NAS National Airspace System

NOTAM Notice to Airman

PIC Pilot In Command

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

SO Safety Observer

SOP Standard Operating Procedures

UAV Unmanned Aircraft Vehicle

UAS Unmanned Aircraft System

VFR Visual Flight Rules

VLOS Visual Line of Site

VMC Visual Meteorological Conditions

VTOL Vertical Takeoff and Landing

SUMMARY 

JASON MENDEZ 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 JASON MENDEZ 

to operate an Unmanned Aircraft System (UAS) for the commercial purpose of conducting 

aerial video and photography of construction sites, real estate, and landscape over certain 

areas of the United States.
INTRODUCTION AND INTERESTS OF THE PETITIONER 

JASON MENDEZ provides his clients with expertise and knowledge in advanced aerial 

technologies. JASON MENDEZ has thousands of hours flying experience ranging from radio 

control airplanes and helicopters of various sizes including UASs and has been a member of 

the Academy of Model Aeronautics since 1995. In addition to his experience with radio 

control aircraft and UASs, JASON MENDEZ is also has over 15 years of professional

experience and a photographer and videographer and is currently a freelance photographer 

for several media outlets in the Fresno area. The objective of JASON MENDEZ and his aerial 

operations is to provide high quality imaging for a variety of commercial, public, and 

residential uses, specifically targeting:

• Commercial, residential and agricultural real-estate marketing

• Construction sites before and after

• Appraisals of commercial, residential and agricultural properties

• Motion Picture Filming

• Wedding Photography

• Newspaper Photography

BACKGROUND 

Unmanned Aircraft Systems: DJI Inspire 1

JASON MENDEZ 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 7 pounds, with a length of 

17 inches and a width of 18 inches and a height of 10 inches and a maximum speed of 

approximately 30 knots.

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

powered electric motors.

The DJI Inspire 1 will be operated by JASON MENDEZ and 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, JASON MENDEZ , pursuant to the provisions of the Federal Aviation Regulations 

(14 C.F.R. § 11.61) and the FAA Modernization and Reform Act of 2012 (FMRA), Section 
333, Special Rules for Certain Unmanned Aircraft Systems, hereby petitions the 

Administrator to commercially operate the DJI Inspire 1 UAS in the National Airspace 

System (NAS), and for an exemption from the requirements of 14 C.F.R §§ 61.113(a) & (b), 

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

& (b).

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

unmanned aircraft and its operation, JASON MENDEZ operation 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, JASON MENDEZ requests relief from Sections 91.405(a), 91.407(a)(1), 

91.409(a)(1) & (a)(2), and 91.417(a) & (b), as these sections set forth requirements for 

maintenance that only apply to aircraft with an airworthiness certificate.

JASON MENDEZ submits that the requested relief is proper since an equivalent level of 

safety will be ensured. JASON MENDEZ will use experienced personnel or technicians to 

perform maintenance, alterations, or preventive maintenance on the UASs using the 

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

Maintenance Log, and DJI Inspire 1 UAS Instruction Manual). Furthermore, JASON MENDEZ 

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

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

privileges and limitations: Pilot in command, is requested by JASON MENDEZ to the

extent necessary to allow a Pilot in Command (PIC) with significant experience in the field of 

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

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

consistent with this exemption, including evasive and emergency maneuvers and 

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

JASON MENDEZ 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, JASON MENDEZ submits that he will ensure 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 UAS Instruction Manual), and that the aircraft are in a condition for safe flight.

JASON MENDEZ 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 UA to the GCS for active monitoring of the flight path. This 

altitude information, combined with JASON MENDEZ’s operation of the DJI Inspire 1 UAS 

within visual line of sight, at or below 400 feet AGL, will ensure a level of safety equivalent to 

Section 91.121.
Additionally, JASON MENDEZ seeks an exemption from the requirements of Section 

91.151(b), entitled Fuel requirements for flight in VFR conditions. JASON MENDEZ submits 

that safety will not be affected by operation of the DJI Inspire 1 UAS during daylight hours in 

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

power to fly for a total duration of approximately 15 minutes to the first point of intended 

landing and, assuming normal cruising speed, to fly after that for at least 5 minutes.

In accordance with 14 C.F.R. § 11.81, JASON MENDEZ provides the following information in 

support of its petition for exemption:

A. Name and Address of the Petitioner. 

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

JASON MENDEZ

6335 E. Heaton Ave. 

Fresno, CA 93727

Jason@jason-mendez.com

(559) 824-1680

B. The Specific Sections of 14 C.F.R. From Which JASON MENDEZ Seeks 

Exemption. 

1. JASON MENDEZ Seeks Exemption from the Requirements of Section 61.113(a) and 

(b). 

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

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

a) No person who holds a private pilot certificate may act as a pilot in command 

(PIC) of an aircraft that is carrying passengers or property for compensation or 

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

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

connection with any business or employment if—

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

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

compensation or hire.

2. JASON MENDEZ Seeks Exemption From The Requirements Of Section 91.7(a). 

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

a) No person may operate a civil aircraft unless it is in an airworthy condition.
3. JASON MENDEZ Seeks Exemption From The Requirements Of Section 91.121. 

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

part:

I. 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--

Below 18,000 feet MSL, to--

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

100 nautical miles of the aircraft;

b) 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

c) 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. JASON MENDEZ Seeks Exemption From The Requirements Of Section 91.151(b). 

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

states the following:

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

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

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

for at least 20 minutes.

5. JASON MENDEZ Seeks Exemption From The Requirement Of Section 91.405(a). 

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

Each owner or operator of an aircraft—

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

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

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

6. JASON MENDEZ Seeks Exemption from the Requirements of Section 91.407(a)(1) 

Section 91.407, entitled Operation after maintenance, preventive maintenance, 

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

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

preventive maintenance, rebuilding, or alteration unless--
(1) It has been approved for return to service by a person authorized 

under § 43.7 of this chapter[.]

7. JASON MENDEZ Seeks Exemption from the Requirements of Sections 91.409(a)(1) 

and 91.409(a)(2). 

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

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

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

(1) An annual inspection in accordance with part 43 of this chapter 

and has been approved for return to service by a person 

authorized by § 43.7 of this chapter; or

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

accordance with part 21 of this chapter.

8. JASON MENDEZ Seeks Exemption from the Requirements of Sections 91.417(a) and 

91.417(b). 

 

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

following:

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

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

specified in paragraph (b) of this section:

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

alteration and records of the 100-hour, annual, progressive, and 

other required or approved inspections, as appropriate, for each 

aircraft (including the airframe) and each engine, propeller, rotor, 

and appliance of an aircraft. The records must include--

1. A description (or reference to data acceptable to the 

Administrator) of the work performed; and

2. The date of completion of the work performed; and

3. The signature and certificate number of the person approving 

the aircraft for return to service.

(2) Records containing the following information:

1. The total time in service of the airframe, each engine, each 

propeller, and each rotor.

2. The current status of life-limited parts of each airframe, engine, 

propeller, rotor, and appliance.

3. The time since last overhaul of all items installed on the aircraft 

which are required to be overhauled on a specified time basis.
4. The current inspection status of the aircraft, including the time 

since the last inspection required by the inspection program 

under which the aircraft and its appliances are maintained.

5. The current status of applicable airworthiness directives (AD) 

and safety directives including, for each, the method of 

compliance, the AD or safety directive number and revision 

date. If the AD or safety directive involves recurring action, the 

time and date when the next action is required.

6. Copies of the forms prescribed by § 43.9(d) of this chapter for 

each major alteration to the airframe and currently installed 

engines, rotors, propellers, and appliances.

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

prescribed:

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

retained until the work is repeated or superseded by other work 

or for 1 year after the work is performed.

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

retained and transferred with the aircraft at the time the aircraft 

is sold.

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

§ 43.11 of this chapter shall be retained until the defects are 

repaired and the aircraft is approved for return to service.

C. The Extent Of Relief JASON MENDEZ Seeks And The Reason JASON 

MENDEZ Seeks The Relief. 

1) Extent Of Relief JASON MENDEZ Seeks And The Reason JASON MENDEZ Seeks Relief 

From Section 61.113(a) And (b). 

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

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

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

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

conduct the proposed UAS flight operations for compensation or hire.

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

state that a private pilot may, for compensation or hire, act as PIC of an aircraft in 

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

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

for compensation or hire.
As set forth more fully below, JASON MENDEZ submits that an equivalent level of 

safety will be maintained because no PIC will be allowed to operate the DJI Inspire 1 

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

demonstrating that the PIC is able to safely operate either the DJI Inspire 1 UAS in a 

manner consistent with the operations specifications as described in this exemption, 

including evasive and emergency maneuvers, as well as maintaining appropriate 

distances from people, vessels, vehicles and structures.

Further, JASON MENDEZ submits that all flights of DJI Inspire 1 UAS, conducted by 

the PIC pursuant to the grant of this Petition: (1) will be incidental to JASON MENDEZ 

business; and (2) will not carry passengers or property for compensation or hire.

2) Extent Of Relief JASON MENDEZ Seeks And The Reason JASON MENDEZ 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 JASON MENDEZ to determine that the DJI Inspire 1 UAS are 

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

with the operating documents (i.e., the JASON MENDEZ Aerial Operations Manual, 

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

JASON MENDEZ 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, JASON MENDEZ will ensure that the DJI Inspire 1 UAS are in airworthy 

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

Maintenance Log, and DJI Inspire 1 UAS 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 JASON MENDEZ Seeks And The Reason JASON MENDEZ Seeks Relief 

From Section 91.121. 

Relief from Section 91.121, entitled Altimeter settings, may be required to allow flight 

operations of the DJI Inspire 1 UAS, which utilize a barometric pressure sensor, GPS 

equipment, and a radio communications telemetry data link to downlink altitude 

information from the UA to the PIC at the ground control station (GCS). Since the FAA 

requires that any altitude information concerning UAS operations be reported to air 

traffic control (ATC) in feet above ground level (AGL), JASON MENDEZ 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, before each 

flight.

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

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

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

safety will be maintained since the DJI Inspire 1 UAS 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 JASON MENDEZ Seeks And The Reason JASON MENDEZ 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 15 minutes to the first point of intended 

landing and, assuming normal cruising speed, to fly after that for at least 5 minutes. 

JASON MENDEZ 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 JASON MENDEZ proposes to conduct pursuant to this Petition.

Significantly, as set forth below, the technical specifications of the DJI Inspire 1 UAS 

operating documents, and JASON MENDEZ proposed operating limitations, ensure 

that JASON MENDEZ will safely operate the battery powered DJI Inspire 1 UASs 

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

rules (VFR), with enough battery power to fly for a total duration of 15 minutes to the 

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

for at least 5 minutes.

5) Extent Of Relief JASON MENDEZ Seeks And The Reason JASON MENDEZ 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, JASON MENDEZ requests relief 

from these Sections because the DJI Inspire 1 UAS do not require airworthiness 

certificates. As set forth more fully below, DJI Inspire 1 UAS meet the conditions of 

FMRA Section 333 for operation without an airworthiness certificate. Accordingly, 

JASON MENDEZ will use trained technicians to perform maintenance, alterations, or 

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

prescribed in the UAS operating documents (i.e., the JASON MENDEZ Aerial 

Operations Manual, Monthly Maintenance Log, and DJI Inspire 1 UAS Instruction 

Manual). Furthermore, JASON MENDEZ will document and maintain all maintenance 

records for the DJI Inspire 1 UAS .

D. The Reasons Why Granting JASON MENDEZ 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 JASON 

MENDEZ to safely, efficiently, and economically perform aerial video and 
photography of construction sites, real estate, and landscape over certain areas of 

the United States.

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

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

JASON MENDEZ 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. 

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

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

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

exemption allowing the use of a DJI Inspire 1 UAS would reduce the amount of 

manned aircraft in the NAS, reduce noise and air pollution, as well as increase the 

safety of life and property in the air and on the ground.

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

congestion around airports caused by arriving and departing aircraft will be reduced. 

The DJI Inspire 1 UAS do not require an airport to takeoff or land. Likewise, a 

reduction of manned aircraft conducting aerial video and photography missions 

would result in fewer aircraft that must be handled by air traffic control during the 

ground, takeoff, departure, arrival, and landing phases of flight operations.

2) The Public Will Benefit From The Safety And Efficiency Of The DJI Inspire 1 UAS 

 

Conducting aerial acquisitions with the DJI Inspire 1 UAS , instead of manned aircraft, 

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

pollution generated during traditional aerial video and still photography flight 

operations. By using battery power and electric motors, the DJI Inspire 1 UAS produce 

no air pollution, and is the most viable environmentally conscious alternative to the 

cabin class, six cylinder internal combustion engine aircraft that are typically utilized 

for aerial video and photography, while burning approximately 20-30 gallons per hour 

of leaded aviation fuel. The DJI Inspire UAS, while reducing the carbon footprint of 

aerial acquisitions, also eliminates noise pollution, as the UAs are propelled by 

battery powered electric motors, rather than an internal combustion engine.

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

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

traditional manned aircraft flight operations, will be substantially reduced or 

completely eliminated. Aside from the lack of flight crew members located onboard 

the aircraft, the DJI Inspire 1 UAS (weighing approximately 6 pounds 7.5 ounces at 

their maximum gross weights with a length of 17.3 inches, width of 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 are also an economical 

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

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

JASON MENDEZ, to remain competitive and contribute to growth of the U.S. economy. 

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

Agency (“EPA”) regulatory actions phasing out leaded aviation fuels, U.S. owned and 

operated companies must adopt new and alternative technology in order to remain 

competitive. Operating the battery powered DJI Inspire 1 UAS is one such technology 

that not only allows companies greater operational flexibility compared to manned 

aircraft, but provides such flexibility without the high operational cost of a traditional 

manned aircraft.

By operating the DJI Inspire 1 UAS , companies such as JASON MENDEZ can remain 

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

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

Improved financial performance of U.S. companies, through commercial use of the 

DJI Inspire 1 UAS, provides a stable workforce that increases consumer spending; 

improves local, state, and federal tax revenues; and allows companies to invest in 

research and development in order to remain competitive both in the United States 

and abroad.

4) There Are No Privacy Issues. 

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

for decades, JASON MENDEZ 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 JASON MENDEZ Aerial Operations 

Manual, Monthly Maintenance Log, and Instruction Manual) which requires property 

owner involvement as well as local law enforcement notification, and in accordance 

with the Federal Aviation Regulations, including the minimum altitude requirements 

of 14 C.F.R. § 91.119.

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

Safety, Or How The Exemption Would Provide A Level Of Safety At Least 

Equal To That Provided By The Rule From Which JASON MENDEZ 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, JASON MENDEZ operation of the DJI 

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

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

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

Transportation shall determine if certain unmanned aircraft systems may operate

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

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

section 334 of this Act.

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

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

i) which types of unmanned aircraft systems, if any, as a result of their size, 

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

areas, and operation within visual line of sight do not create a hazard to users 

of the national airspace system or the public or pose a threat to national 

security; and

ii) whether a certificate of waiver, certificate of authorization, or airworthiness 

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

for the operation of unmanned aircraft systems identified under paragraph 

(1).

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

that certain unmanned aircraft systems may operate safely in the national 

airspace system, the Secretary shall establish requirements for the safe 

operation of such aircraft systems in the national airspace system.

In seeking this exemption, JASON MENDEZ 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 Phantom 3 UASs; (b) the pilot certification requirement; and 

(c) the specific operating limitations.

a) The Specifications Of The DJI Inspire 1 UAS Demonstrate Its Safe Characteristics.

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

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

operational capability.
1. Technical Specifications of DJI Inspire 1 UAS.

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

Manuals, attached hereto as Appendix A and B.

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

UASs 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 provided in the User Manual, attached hereto as 

Appendix A.

3. The DJI Inspire 1 UAS is Designed For Automatic Return To Home Point Or 

Hover In The Event Of Loss Of The Control Link Or Navigation.

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

flight, for 3 seconds or more. If, after 3 seconds, the DJI Inspire 1 UAS 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., failsafe mode) via 

GPS, and will descend to the takeoff position and shutdown.

A complete description of the Failsafe Functions of the UAS are set forth in 

pages 27 through 29. The DJI Inspire 1 User Manual is attached here as 

Appendix A.

4. DJI Inspire 1 UAS GCS Operation.

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

GCS and flight control software is provided in the “Flight Test” portion of their 

respective user manuals.

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.

JASON MENDEZ will be the only person to act as a pilot in command (PIC) of DJI 

Inspire 1 UAS. Additionally, a safety observer will assist him during flight time.

c) Flights Of DJI Inspire 1 UAS will Be Conducted Pursuant To Specific Operating 

Limitations.

In seeking this exemption, JASON MENDEZ proposes to commercially operate DJI 

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

over certain areas of United States, pursuant to the following specific operating 

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

following aircraft described in the operating documents, rotorcraft UASs 

weighing less than 55 pounds maximum gross weight: DJI Inspire 1 UAS. 

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 45 knots.

4. The UA must be operated at an altitude of no more than 400 feet above 

ground level (AGL), as indicated by the procedures specified in the operating 

documents unless a special request is made and approved by ATC. All 

altitudes reported to ATC must be in feet AGL.

5. The UAs must be operated within visual line of sight (VLOS) of the PIC at all 

times. This requires the PIC to be able to use human vision unaided by any 

device other than corrective lenses, as specified on the PIC’s FAA-issued 

airman medical certificate.

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

permitted.

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

satisfy the VLOS requirement as long as the PIC always maintains VLOS 

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

Electronic messaging or texting is not permitted during flight operations. The 

PIC must be designated before the flight and cannot transfer his or her 

designation for the duration of the flight. The PIC must ensure that the SO can 

perform the functions prescribed in the operating documents.

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

seeing and avoiding other air traffic and other ground based 

obstacles/obstructions and is not permitted to operate the camera or other 

instruments.

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

during UAS operations and made available to the Administrator upon request. 

If a discrepancy exists between the conditions and limitations contained in the 

grant of exemption and the procedures outlined in the operating documents, 

the conditions and limitations contained in the grant of exemption take 

precedence and must be followed. Otherwise, the operator must follow the 

procedures as outlined in its operating documents. The operator may update 

or revise its operating documents. It is the operator’s responsibility to track 

such revisions and present updated and revised documents to the 

Administrator upon request. The operator must also present updated and 
revised documents if it petitions for extension or amendment to the grant of 

exemption. If the operator determines that any update or revision would affect 

the basis upon which the FAA granted the exemption, then the operator must 

petition for amendment to its grant of exemption. The FAA’s UAS Integration 

Office (AFS-80) may be contacted if questions arise regarding updates or 

revisions to the operating documents.

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

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

safe operation of the UAS, the aircraft is prohibited from operating until the 

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

condition for safe flight. The Ground Control Station must be included in the 

preflight inspection. All maintenance and alterations must be properly 

documented in the aircraft records.

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

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

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

functional test flight must make an entry in the aircraft records.

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

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

relevant sections of the operating documents.

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

maintenance, overhaul, replacement, inspection, and life limit requirements.

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

requirements, in accordance with the operating documents. Maintenance, 

inspection, alterations, and status of replacement/overhaul component parts 

must be noted in the aircraft records, including total time in service, 

description of work accomplished, and the signature of the authorized person 

returning the UAS to service.

15.Each UASs operated under this exemption must comply with all manufacturer 

Safety Bulletins.

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

corrective action taken against discrepancies discovered between 

inspections.

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

third- class medical certificate.

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

operator’s qualification criteria and demonstrates the ability to safely operate 

the UAS in a manner consistent with how the UAS will be operated under the 
exemption, including evasive and emergency maneuvers and maintaining 

appropriate distances from persons, vessels, vehicles and structures. PIC 

qualification flight hours must be logged in a manner consistent with 14 C.F.R. 

§ 61.51(b). Flights for the purposes of training the operator’s PICs are 

permitted under the terms of the exemption. However, training operations 

may only be conducted during dedicated training sessions. During training, 

proficiency, and 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 UAV 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 UAV may not be operated less than 500 feet below or less than 2,000 

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

from the PIC.

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

pre- 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 documents.

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

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

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

remaining.

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

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

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

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

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

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

altitude level and potential transponder requirements.
26.All aircraft operated in accordance with the exemption must be identified by 

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

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

Subpart C. Markings must be as large as practicable.

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

operation and control of the UAV must comply with the Federal 

Communications Commission (FCC) or other appropriate government 

oversight agency requirements.

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

available to the PIC at the Ground Control Station of the UAS any time the UAS 

is operating. These documents must be made available to the Administrator 

or any law enforcement official upon request.

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

operations and activities at all times.

30.The UAV 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:

(1) Barriers or structures are present that sufficiently protect nonparticipating 

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

operator must ensure that nonparticipating persons remain under such 

protection. If a situation arises where nonparticipating persons leave such 

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

immediately and/or;

(2) The aircraft is operated near vessels, vehicles or structures where the 

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

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

operating closer to those objects and determined that it does not present 

an undue hazard, and;

(3) Operations nearer to the PIC, SO, operator trainees or essential persons 

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

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

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

Permission from land owner/controller or authorized representative will be 

obtained for each flight to be conducted.
33.Any incident, accident, or flight operation that transgresses the lateral or 

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

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

Accidents must be reported to the National Transportation Safety Board 

(NTSB) per instructions contained on the NTSB Web site: www.ntsb.gov.

2) Reasons Why An Exemption From The Requirements Of Section 61.113(a) And (b) 

Would Not Adversely Affect Safety. 

JASON MENDEZ submits that the equivalent level of safety established by Section 

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

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

and currency requirements, that the PIC is able to safely operate the DJI Inspire 1 

UAS in a manner consistent with the exemption, including evasive and emergency 

maneuvers and maintaining appropriate distances from people, vessels, vehicles and 

structures.

Considering JASON MENDEZ proposed area of operations, and the operating 

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

requirements to those of commercial pilot requirements (See Exemption No. 11062); 

and the airmanship skills necessary to safely operate the DJI Inspire 1 UAS, JASON 

MENDEZ submits that the additional manned airmanship experience of a 

commercially certificated pilot would not correlate to the airmanship skills necessary 

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).

JASON MENDEZ will not allow any PIC to operate the DJI Inspire 1 UAS unless the PIC 

has demonstrated, by meeting minimum flight-hour requirements or the DJI Inspire 1 

UAS training and currency requirements, that the PIC is able to safely operate the DJI 

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

emergency maneuvers and maintaining appropriate distances from people, vessels, 

vehicles and structures.

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

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

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

to be used for operations under the exemption). In addition to the hour requirements, 

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

currency purposes).

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

that was obtained in compliance with applicable regulations will ensure an equivalent 
level of safety during JASON MENDEZ proposed operations. The Administrator has 

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

applicable regulations would ensure safe operations, stating as follows:

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

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

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

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

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

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

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

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

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

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

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

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

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

requirements in Exemption No. 11062 are appropriate to practice and build 

proficiency in the skills necessary to safely conduct the petitioner’s proposed 

operations. The FAA also finds that prior documented flight experience that was 

obtained in compliance with applicable regulations would satisfy this 

requirement. Training, proficiency, and experience-building flights can also be 

conducted under the grant of exemption to accomplish the required flight time. 

During training, proficiency, and experience-building flights the PIC is required to 

operate the UAS with appropriate distances in accordance with 14 C.F.R 91.119.

Exemption No. 11138 at page 15.

Accordingly, JASON MENDEZ will ensure safe operations by not allowing any PIC to 

operate DJI Inspire 1 UAS unless that PIC has demonstrated, by meeting minimum 

flight-hour and currency requirements, that the PIC is able to safely operate the DJI 

Inspire 1 UAS in a manner consistent with the exemption, including evasive and 

emergency maneuvers and maintaining appropriate distances from people, vessels, 

vehicles and structures.

3) Reasons Why An Exemption From The Requirements Of Section 91.7(a) Would Not 

Adversely Affect Safety. 

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

because prior to every flight, JASON MENDEZ will ensure that DJI Inspire 1 UAS is in 

an airworthy condition based upon the UAS’s compliance with its operating 

documents and as stated in the conditions and limitations herein.

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

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

Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 
11110, 11112, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 

11160, 11161).

4) Reasons Why An Exemption From The Requirements Of Section 91.121 Would Not 

Adversely Affect Safety. 

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

because the altitude information of the DJI Inspire 1 UAS will be provided to the PIC 

via GPS equipment and a radio communications telemetry data link, which downlinks 

from the UA to the GCS for active monitoring of the flight path and altitude. This 

altitude information, combined with JASON MENDEZ operation of the DJI Inspire 1 

UAS within visual line of sight, at or below 400 feet AGL, will ensure a level of safety 

equivalent to Section 91.121. The altitude information will be generated by GPS 

equipment installed onboard the aircraft. Prior to each flight, a zero altitude initiation 

point is automatically established by the UASs at ground level.

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

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

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

11112, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 

11161).

5) Reasons Why An Exemption From The Requirements Of Section 91.151(b) Would Not 

Adversely Affect Safety. 

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

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

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

location of the proposed flight operations. Accordingly, JASON MENDEZ 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 15 minutes 

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

that for at least 5 minutes.

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

UAS ; the limitations on the proposed flight operations; and the location of the 

proposed operations, will ensure an equivalent level of safety established by 14 

C.F.R. Section 91.151(b). Furthermore, safety will be ensured as the DJI Inspire 1 

UAS provide audible and visual warnings to the PIC at the GCS when the UAs 

experiences low battery voltage, the first warning occurring at approximately 33% 

remaining battery power, and again at approximately 10% remaining battery power. 

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

automatically.

Significantly, previous exemptions granted by the FAA concerning Section 91.151 

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

operating limitations of the UAS are considered. Relief has been granted for manned 
aircraft to operate at less than the minimums prescribed in Section 91.151, including 

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

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

respects, to those presented herein (e.g. Exemption Nos. 8811, 10808, 10673, 

11042, 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 

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

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

91.407(a)(1), 91.409(a)(1) & (a)(2), And 91.417(a) & (b) Would Not Adversely Affect 

Safety. 

In seeking this exemption, JASON MENDEZ submits that the equivalent level of safety 

with regard to the regulatory maintenance and alteration requirements established 

by Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) will 

be met because JASON MENDEZ 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 

JASON MENDEZ Aerial Operations Manual, Monthly Maintenance Log, and DJI Inspire 

1 Instruction Manual). Furthermore, JASON MENDEZ will document and maintain all 

maintenance records for the DJI Inspire 1 UAS .

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

documents, JASON MENDEZ will maintain the equivalent level of safety established 

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

User Manuals are attached here as Appendix A.

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

MENDEZ will use trained technicians to perform maintenance, alterations or 

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

prescribed by the operating documents.

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

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

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

documented and maintained utilizing the monthly maintenance log.

Significantly, previous exemptions granted by the FAA concerning Sections 

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

safety is not adversely affected when the technical characteristics and operating 

limitations of the UAS are considered.

In consideration of JASON MENDEZ proposed operating limitations, the operating 

documents, and the technical aspects of the DJI Inspire 1 UAS, JASON MENDEZ 

submits that safety will not be adversely affected by granting exemption from 14 

C.F.R. Sections 91.405(a), 91.407(a)(1) and (a)(2), 91.409(a)(2), and 91.417(a) and 

(b). The FAA has previously granted relief specific to UAS in circumstances similar, in 

all material respects, to those presented herein (e.g. Exemption Nos. 11062, 11063, 
11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112, 11136, 11138, 

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

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

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

(FMRA) and 14 C.F.R. § 21.16 entitled Special Conditions, JASON MENDEZ requests 

that the FAA prescribe special conditions for the intended operation of the DJI Inspire 

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

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

Subpart H, and 14 C.F.R §§ 61.113(a) & (b), 91.7 (a), 91.121, 91.151(b), 91.405(a),

91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b). Such special conditions will 

permit safe operation of the UAs for the limited purpose of conducting aerial video 

and photography over certain areas of the United States for compensation or hire. 

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

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

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

airworthiness certification in accordance with any requirements that must be 

established for the safe operation of the UAS in the NAS.

Likewise, the Administrator may prescribe special conditions pursuant to 14 C.F.R. § 

21.16, for operation of the DJI Inspire 1 UAS, since the airworthiness regulations of 

14 C.F.R. Part 21 do not contain adequate or appropriate safety standards, due to 

the novel or unusual design features of the aircraft. Section 21.16, entitled Special 

Conditions, states the following:

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

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

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

engine or propeller, he prescribes special conditions and amendments thereto for 

the product. The special conditions are issued in accordance with Part 11 of this

chapter and contain such safety standards for the aircraft, aircraft engine or 

propeller as the FAA finds necessary to establish a level of safety equivalent to 

that established in the regulations.

See 14 C.F.R. § 21.16.

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

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

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

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

Subpart H, and 14 C.F.R Sections 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 

91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b).
• A Summary That Can Be Published In The Federal Register, stating: The Rules From 

Which JASON MENDEZ Seeks Exemption: 

JASON MENDEZ 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 JASON MENDEZ Seeks: 

This exemption will permit JASON MENDEZ to commercially operate an Unmanned 

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

over certain areas of the United States.

• Any Additional Information, Views, Or Arguments Available To Support JASON 

MENDEZ Request. 

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

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

certain UAS may operate safely in the NAS. As such, JASON MENDEZ request for 

exemption may be granted pursuant to the authority of FMRA Section 333 and 14 C.F.R. 

Part 11, as set forth above.

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

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

national security; and further, provides the authority for such UAS to operate 

without airworthiness certification.

As discussed in detail above, JASON MENDEZ 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, JASON MENDEZ seeks an exemption pursuant to 14 C.F.R. §

11.61 and Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA), which 

will permit safe operation of the DJI Inspire 1 UAS commercially, without an airworthiness 

certificate, for the limited purpose of conducting aerial video and photography over certain 

areas of the United States. By granting this Petition, the FAA Administrator will be fulfilling 

the Congressional mandate of the FAA Modernization and Reform Act of 2012, while also 

advancing the interests of the public, by allowing JASON MENDEZ to safely, efficiently, 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, JASON MENDEZ respectfully requests 

that the Administrator grant this Petition for an exemption from the requirements of 14 

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

91.409(a)(1) & (a)(2), and 91.417(a) & (b), and permit Leading Edge to operate the DJI 

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

certain areas of the United States.

Dated: October 19, 2015

Attachments to this submission:

1. DJI Inspire 1 Manual

2. UAS Flight/Maintenance Log

JASON MENDEZ only utilizes safe and reliable UASs. DJI is an industry leader in small UAS 

production. DJI UASs are loaded with ground breaking software enabling the user to set 

parameters which will not allow flight into controlled airspace. Parameters can also be set to 

limit flight to no higher than a predetermined and set altitude as well as limit flight to a 

predetermined and set distance. In addition, DJI software provides real- time altitude and 

location information to the PIC via the linked monitor (smart phone/tablet devices)

Very respectfully, 

JASON MENDEZ 

6335 E. Heaton Ave 

Fresno, CA 93727 

(559) 824-1680 

Jason@jason-mendez.com 

Maximum upload to this site would not support my attachments: I've added the following 

links instead:

1. DJI Inspire 1 Manual

http://download.djiinnovations.com/downloads/inspire_1/en/Inspire_1_User_Manual_v1.2_en.pdf