UNITED STATES OF AMERICA

DEPARTMENT OF TRANSPORTATION

FEDERAL AVIATION ADMINISTRATION

WASHINGTON, DC

IN THE MATTER OF THE PETITION FOR EXEMPTION OF:

ANDREW L. CHROSTOWSKI

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 THE DJI INSPIRE 1 UNMANNED

AIRCRAFT SYSTEM PURSUANT TO SECTION 333 OF THE FAA MODERNIZATION

AND REFORM ACT OF 2012 (PUBLIC LAW 112­95)

SUBMITTED ON

January 10, 2015

ANDREW L. CHROSTOWSKI

1409 WEST 29TH STREET

ERIE, PA 16508

(814) 882­7665

TABLE OF CONTENTS
1

GLOSSARY OF

ABBREVIATIONS..................................................................................................2

SUMMARY...................................................................................................3

INTRODUCTION AND INTERESTS OF PETITIONER..........................................3

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

BASIS FOR PETITION....................................................................................4

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

THE SPECIFIC SECTIONS OF 14 C.F.R. FROM WHICH ANDREW L.

CHROSTOWSKI SEEKS EXEMPTION...............................................................7

THE EXTENT OF RELIEF ANDREW L. CHROSTOWSKI SEEKS AND THE

REASON ANDREW L. CHROSTOWSKI SEEKS THE RELIEF..............................11

THE REASONS WHY GRANTING ANDREW L. CHROSTOWSKI’S REQUEST

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

THE REASONS WHY GRANTING THE EXEMPTION WOULD NOT

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

CONCLUSION.............................................................................................31

GLOSSARY OF ABBREVIATIONS
2

AGL ABOVE GROUND LEVEL

AOI AREA OF INTEREST

ATC AIR TRAFFIC CONTROL

ATO AIR TRAFFIC ORGANIZATION

AV AERIAL VEHICLE

CFR CODE OF FEDERAL REGULATIONS

COA CERTIFICATE OF AUTHORIZATION

FAA FEDERAL AVIATION ADMINISTRATION

FAR FEDERAL AVIATION REGULATION

GCS GROUND CONTROL STATION

GPS GLOBAL POSITIONING SYSTEM

LOL LOSS OF LINK

NAS NATIONAL AIRSPACE SYSTEM

NOTAM NOTICE TO AIRMAN

PIC PILOT IN COMMAND

SECTION 333 FAA MODERNIZATION AND REFORM ACT OF 2012 (FMRA)

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 TAKE OFF AND LANDING

DJI UAV MANUFACTURER

ESC ELECTRONIC SPEED CONTROL

FPV FIRST PERSON VIEW

LI­PO LITHIUM POLYMER BATTERY

RCV RADIO CONTROLLED VEHICLE

SUMMARY
3

ANDREW L. CHROSTOWSKI, OPERATING UNDER THE COMPANY TITLE, ELITE

A/V SOLUTIONS 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 ANDREW L. CHROSTOWSKI

TO OPERATE AN UNMANNED AIRCRAFT SYSTEM (UAS) FOR THE

COMMERCIAL PURPOSE OF CONDUCTING AERIAL VIDEO AND

PHOTOGRAPHY FOR MARKETING, FILM SETS, REAL ESTATE PHOTOGRAPHY,

COMMERCIALS, SPECIAL EVENTS, WEDDING CINEMATOGRAPHY, MARINE

PHOTOGRAPHY AND VIDEOGRAPHY, ROOFING INSPECTION, AND

LANDSCAPE IMAGING OVER CERTAIN AREAS OF THE UNITED STATES.

INTRODUCTION AND INTERESTS OF THE PETITIONER

MY NAME IS ANDREW L. CHROSTOWSKI, AND I AM AN AERIAL RCV

ENTHUSIAST WITH OVER 5 YEARS OF EXPERIENCE OPERATING VARIOUS

TYPES OF AERIAL RCV’S AS WELL AS 1 YEAR OPERATING QUADCOPTER

UAS’S. ANDREW L. CHROSTOWSKI ALSO PROVIDES CUSTOMERS HIGH

QUALITY PHOTOGRAPHY AND VIDEOGRAPHY FOR A WIDE RANGE OF

APPLICATIONS. ANDREW L. CHROSTOWSKI IS CONSIDERED AN ADVANCED

LEVEL RCV PILOT, WHO HAS EVEN TAUGHT BEGINNERS HOW TO PILOT

RCV’S.

THE OBJECTIVE OF ELITE A/V SOLUTIONS IS TO PROVIDE SUPERIOR

AERIAL IMAGING FOR A WIDE RANGE OF INDUSTRIES AND EVENTS WHILE

PROMOTING SAFE UAS OPERATIONS AND PROMOTING PUBLIC KNOWLEDGE

OF UAS’S AS WELL AS PROVIDING A HIGH LEVEL OF KNOWLEDGE ABOUT

UAS’S.

BACKGROUND
4

UNMANNED AIRCRAFT SYSTEMS: DJI INSPIRE 1 UAS

ANDREW L. CHROSTOWSKI SEEKS AN EXEMPTION TO OPERATE THE

DJI SYSTEM 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 6 POUNDS 4 OUNCES, WHILE

HAVING A LENGTH OF APPROXIMATELY 17 INCHES, WIDTH OF 17 INCHES,

HEIGHT OF 11 INCHES, AND A MAXIMUM SPEED OF APPROXIMATELY 42

KNOTS. THE DJI INSPIRE 1 IS EQUIPPED WITH FOUR MAIN ROTORS; DRIVEN

BY A LITHIUM POLYMER BATTERY POWERED ELECTRIC MOTOR.

THE DJI INSPIRE 1 UAS THAT WILL BE OPERATED BY ANDREW L.

CHROSTOWSKI 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 MARKINGS.

BASIS FOR PETITION

PETITIONER, ANDREW L. CHROSTOWSKI, 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, ANDREW L. CHROSTOWSKI’S OPERATION OF THE 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.
5

ACCORDINGLY, ANDREW L. CHROSTOWSKI 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.

ANDREW L. CHROSTOWSKI SUBMITS THAT THE REQUESTED RELIEF IS

PROPER SINCE AN EQUIVALENT LEVEL OF SAFETY WILL BE ENSURED.

ANDREW L. CHROSTOWSKI WILL USE EXPERIENCED PERSONNEL OR

TECHNICIANS TO PERFORM MAINTENANCE, ALTERATIONS, OR

PREVENTATIVE MAINTENANCE ON THE UAS USING THE METHODS,

TECHNIQUES, AND PRACTICES PRESCRIBED IN THE OPERATING DOCUMENTS

(IE: MONTHLY MAINTENANCE LOG, AND DJI INSPIRE 1 MANUAL)

FURTHERMORE, ANDREW L. CHROSTOWSKI WILL DOCUMENT AND

MAINTAIN ALL MAINTENANCE RECORDS FOR THE DJI INSPIRE 1.

RELIEF FROM CERTAIN REQUIREMENTS OF SECTION 61.113(A) AND (B),

ENTITLED PRIVATE PILOT PRIVILEGES AND LIMITATIONS: PILOT IN

COMMAND, IS REQUESTED BY ANDREW L. CHROSTOWSKI TO THE EXTENT

NECESSARY TO ALLOW A PILOT IN COMMAND (PIC) HOLDING A PRIVATE

PILOT OR HIGHER LEVEL CERTIFICATE, AS WELL AS AN AIRMAN MEDICAL

CERTIFICATE, AND WHO HAS DEMONSTRATED, BY MEETING MINIMUM

FLIGHT ­ HOUR AND CURRENCY REQUIREMENTS, THAT THE PIC IS ABLE TO

SAFELY OPERATE THE DJI INSPIRE 1 UAS IN A MANNER CONSISTENT WITH

THIS EXEMPTION, INCLUDING EVASIVE AND EMERGENCY MANEUVERS AND

MAINTAINING APPROPRIATE DISTANCES FROM PEOPLE, VESSELS, VEHICLES,

AND STRUCTURES.
6

ANDREW L. CHROSTOWSKI SEEKS RELIEF FROM SECTION 91.7(A),

ENTITLED CIVIL AIRCRAFT WORTHINESS, BECAUSE THE DJI INSPIRE 1 UAS

DOES NOT REQUIRE AN AIRWORTHINESS CERTIFICATE IN ACCORDANCE

WITH 14 C.F.R. PART 21, SUBPART H. AS SUCH, ANDREW L. CHROSTOWSKI

SUBMITS THAT HE WILL ENSURE THAT THE DJI INSPIRE 1 UAS IS IN

AIRWORTHY CONDITION PRIOR TO EVERY FLIGHT, BY DETERMINING THAT

THE UAS IS IN COMPLIANCE WITH THE OPERATING DOCUMENTS (I.E.,

MONTHLY MAINTENANCE LOG, AND DJI INSPIRE 1 INSTRUCTION MANUAL),

AND THAT THE AIRCRAFT IS IN A CONDITION FOR SAFE FLIGHT.

ANDREW L. CHROSTOWSKI 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 UAS TO THE GCS FOR ACTIVE

MONITORING OF THE FLIGHT PATH. THIS ALTITUDE INFORMATION,

COMBINED WITH ANDREW L. CHROSTOWSKI’S OPERATION OF THE DJI

INSPIRE 1 UAS WITHIN VISUAL LINE OF SIGHT, AT OR BELOW 500 FEET AGL,

WILL ENSURE A LEVEL OF SAFETY EQUIVALENT TO SECTION 91.121.

ADDITIONALLY, ANDREW L. CHROSTOWSKI SEEKS AN EXEMPTION

FROM THE REQUIREMENTS OF SECTION 91.151(B), ENTITLED FUEL

REQUIREMENTS FOR FLIGHT IN VFR CONDITIONS. ANDREW L.

CHROSTOWSKI 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 18 MINUTES TO THE FIRST POINT OF INTENDED LANDING

AND, ASSUMING NORMAL CRUISING SPEED, TO FLY AFTER THAT FOR AT

LEAST 4.5 MINUTES.

IN ACCORDANCE WITH 14 C.F.R 11.81, ANDREW L. CHROSTOWSKI

PROVIDES THE FOLLOWING INFORMATION IN SUPPORT OF ITS PETITION

FOR EXEMPTION:

A. NAME AND ADDRESS OF THE PETITIONER.
7

THE NAME AND ADDRESS OF THE PETITIONER AND POINT OF

CONTACT IS:

ANDREW L. CHROSTOWSKI

1409 WEST 29TH STREET

ERIE, PA 16508

(814) 882.7665

EMAIL: ​ELITEAVS814TV@GMAIL.COM

A. THE SPECIFIC SECTIONS OF 14 C.F.R. FROM WHICH ANDREW L.

CHROSTOWSKI SEEKS EXEMPTION.

1. ANDREW L. CHROSTOWSKI SEEKS EXEMPTION FROM THE

REQUIREMENTS OF SECTION 61.113(A) AND (B).

SECTION 61.113, ENTITLED PRIVATE 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 PROPERTY OR PASSENGERS 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 IDENTICAL TO THAT

BUSINESS OR EMPLOYMENT; AND (2) THE AIRCRAFT DOES NOT

CARRY PASSENGERS OR PROPERTY FOR COMPENSATION OR

HIRE.

2. ​ANDREW L. CHROSTOWSKI SEEKS EXEMPTION FROM THE

​REQUIREMENTS OF SECTION 91.7(A).

SECTION 91.7, ENTITLED CIVIL AIRCRAFT WORTHINESS, SUBSECTION

(A), STATES THE FOLLOWING: (A) NO PERSON MAY OPERATE A CIVIL

AIRCRAFT UNLESS IT IS IN AN AIRWORTHY CONDITION.

3. ​ANDREW L. CHROSTOWSKI SEEKS EXEMPTION FROM THE

​REQUIREMENTS OF SECTION 91.121.
8

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 ­­ BELOW 18,000 FEET MSL, TO­­

THE CURRENT REPORTED ALTIMETER SETTING OF A STATION

ALONG THE ROUTE AND WITHIN 100 NAUTICAL MILES OF THE

AIRCRAFT;

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;

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. ​ANDREW L. CHROSTOWSKI 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 ALL

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. ​ANDREW L. CHROSTOWSKI SEEKS EXEMPTION FROM THE

REQUIREMENTS OF SECTION 91.405(A).

SECTION 91.405, ENTITLED MAINTENANCE REQUIRED, SUBSECTION (A),
9

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 INSPECTIONS,

EXCEPT AS PROVIDED IN PARAGRAPH (C) OF THIS SECTION,

HAVE DISCREPANCIES REPAIRED AS PRESCRIBED IN PART 43 OF

THIS CHAPTER.

6. ​ANDREW L. CHROSTOWSKI SEEKS EXEMPTION FROM THE

REQUIREMENTS OF SECTION 91.407(A)(1)

SECTION 91.407(A)(1), 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 AN AUTHORIZED

PERSON UNDER 43.7 OF THIS CHAPTER.

7. ​ANDREW L. CHROSTOWSKI 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. ​ANDREW L. CHROSTOWSKI SEEKS EXEMPTION FROM THE

REQUIREMENTS OF SECTIONS 91.417(A) AND 91.417(B).
10

SECTION 91.417, ENTITLED MAINTENANCE RECORDS, SUBSECTIONS (A)

AND (B), STATE THE FOLLOWING:

A. EXCEPT FOR WORK PERFORMED IN ACCORDANCE WITH 91.411

AND 91.413, EACH REGISTERED OWNER OR OPERATOR SHALL

KEEP THE FOLLOWING RECORDS FOR THE PERIODS SPECIFIED

IN PARAGRAPH (B) OF THIS SECTION:

1. RECORDS OF THE MAINTENANCE, PREVENTIVE

MAINTENANCE, AND ALTERATION AND RECORDS OF THE 100­

HOUR, ANNUAL, PROGRESSIVE, AND OTHER REQUIRED OR

APPROVED INSPECTIONS, AS APPROPRIATE, FOR EACH

AIRCRAFT (INCLUDING THE AIRFRAME) AND EACH ENGINE,

PROPELLER, ROTOR, AND APPLIANCE OF AN AIRCRAFT. THE

RECORDS MUST INCLUDE­­

(I) A DESCRIPTION (OR REFERENCE TO DATA ACCEPTABLE

TO THE ADMINISTRATOR) OF THE WORK

PERFORMED; AND

(II) THE DATE OF COMPLETION OF THE WORK PERFORMED

AND

(III) THE SIGNATURE, AND CERTIFICATE NUMBER OF THE

PERSON APPROVING THE AIRCRAFT FOR RETURN TO

SERVICE.

2. RECORDS CONTAINING THE FOLLOWING INFORMATION:

(I) THE TOTAL TIME IN SERVICE OF THE AIRFRAME, EACH

ENGINE, EACH PROPELLER, AND EACH ROTOR.

(II) THE CURRENT STATUS OF LIFE LIMITED PARTS OF

EACH AIRFRAME, ENGINE, PROPELLER, ROTOR, AND

APPLIANCE.

(III) THE TIME SINCE LAST OVERHAUL OF ALL ITEMS

INSTALLED ON THE AIRCRAFT WHICH ARE REQUIRED TO

BE OVERHAULED ON A SPECIFIED TIME BASIS.

(IV) THE CURRENT INSPECTION STATUS OF THE AIRCRAFT,

INCLUDING THE TIME SINCE THE LAST INSPECTION

REQUIRED BY THE INSPECTION PROGRAM UNDER WHICH
11

THE AIRCRAFT AND ITS APPLIANCES ARE MAINTAINED.

(V) THE CURRENT STATUS OF APPLICABLE

AIRWORTHINESS DIRECTIVES (AD)

AND SAFETY DIRECTIVES INCLUDING, FOR EACH, THE

METHOD OF COMPLIANCE, THE AD OR SAFETY DIRECTIVE

NUMBER AND REVISION DATE. IF THE AD OR SAFETY

DIRECTIVE INVOLVES RECURRING ACTION, THE TIME AND

DATE WHEN THE NEXT ACTION IS REQUIRED.

(VI) COPIES OF THE FORMS PRESCRIBED BY 43.9(D) OF THIS

CHAPTER FOR EACH MAJOR ALTERATION TO THE

AIRFRAME AND CURRENTLY INSTALLED ENGINES,

ROTORS, PROPELLERS, AND APPLIANCES.

3. THE OWNER OR OPERATOR SHALL RETAIN THE FOLLOWING

RECORDS FOR THE PERIODS PRESCRIBED:

(I) 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 WORK IS PERFORMED.

(II) 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.

(III) 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.

B. THE EXTENT OF RELIEF ANDREW L. CHROSTOWSKI SEEKS AND THE

REASON ANDREW L. CHROSTOWSKI SEEKS THE RELIEF.

1. EXTENT OF RELIEF ANDREW L. CHROSTOWSKI SEEKS AND THE

REASON ANDREW L. CHROSTOWSKI 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
12

ALLOW A PIC HOLDING A PRIVATE PILOT OR HIGHER LEVEL

CERTIFICATE, AS WELL AS CURRENT AND VALID AIRMAN

MEDICAL CERTIFICATE, AND WHO HAS MET CERTAIN

FLIGHT­HOUR 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, ANDREW L.

CHROSTOWSKI 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 IS ABLE TO SAFELY

OPERATE 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.

FURTHERMORE, ANDREW L. CHROSTOWSKI SUBMITS

THAT ALL FLIGHTS OF THE DJI INSPIRE 1 UAS, CONDUCTED BY THE PIC

PURSUANT TO THE GRANT OF THIS PETITION: (1) WILL BE INCIDENTAL

TO ANDREW L. CHROSTOWSKI’S BUSINESS; AND (2) WILL NOT CARRY

PASSENGERS OR PROPERTY FOR COMPENSATION OR HIRE.

2. EXTENT OF RELIEF ANDREW L. CHROSTOWSKI SEEKS AND THE

REASON ANDREW L. CHROSTOWSKI SEEKS RELIEF FROM

SECTION 91.7(A).

RELIEF FROM SECTION 91.7(A) ENTITLED CIVIL AIRCRAFT

WORTHINESS, IS REQUESTED TO THE EXTENT REQUIRED TO ALLOW

ANDREW L. CHROSTOWSKI TO DETERMINE THAT THE DJI INSPIRE 1

UAS IS IN AIRWORTHY CONDITION PRIOR TO EVERY FLIGHT BY

ENSURING THAT THE UAS IS IN COMPLIANCE WITH THE OPERATING

DOCUMENTS (I.E., ANDREW L. CHROSTOWSKI’S AERIAL OPERATIONS
13

MANUAL, MONTHLY MAINTENANCE LOG, AND DJI INSPIRE 1

INSTRUCTION MANUAL, PRE­FLIGHT CHECKLIST).

ANDREW L. CHROSTOWSKI SEEKS THE REQUESTED RELIEF

BECAUSE THE DJI INSPIRE 1 UAS DOES NOT REQUIRE AN

AIRWORTHINESS CERTIFICATE IN ACCORDANCE WITH 14 C.F.R. PART

21, SUBPART H. THEREFORE, ANDREW L. CHROSTOWSKI WILL ENSURE

THAT THE DJI INSPIRE 1 UAS IS IN AIRWORTHY CONDITION BASED

UPON ITS COMPLIANCE WITH THE OPERATING DOCUMENTS (I.E.,

MONTHLY MAINTENANCE LOG, AND DJI INSPIRE 1 INSTRUCTION

MANUAL) PRIOR TO EVERY FLIGHT, AND FURTHER, DETERMINE THAT

THE AIRCRAFT IS IN CONDITION FOR SAFE FLIGHT, AS STATED IN THE

CONDITIONS AND LIMITATIONS BELOW.

3. EXTENT OF RELIEF ANDREW L. CHROSTOWSKI SEEKS AND THE

REASON ANDREW L. CHROSTOWSKI 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 UTILIZES 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), ANDREW L. CHROSTOWSKI SEEKS THE

REQUESTED RELIEF BECAUSE THE DJI INSPIRE 1 UAS’S ALTIMETER

MAY BE SET ON THE GROUND TO ZERO FEET AGL, RATHER THAN THE

LOCAL BAROMETRIC PRESSURE OR FIELD ALTITUDE, BEFORE EACH

FLIGHT.

CONSIDERING THE LIMITED ALTITUDE OF THE PROPOSED

OPERATIONS, RELIEF FROM 14 CFR 91.121 IS SOUGHT TO THE EXTENT

NECESSARY TO COMPLY WITH THE APPLICABLE CONDITIONS AND

LIMITATIONS STATED BELOW. AS MORE FULLY SET FORTH HEREIN,

AN EQUIVALENT LEVEL OF SAFETY WILL BE MAINTAINED SINCE THE

DJI INSPIRE 1 UAS IS EQUIPPED WITH A BAROMETRIC PRESSURE

SENSOR AND GPS EQUIPMENT, WHICH AUTOMATICALLY ENSURES

THAT A GROUND LEVEL PRESSURE SETTING WILL BE ESTABLISHED
14

PRIOR TO EACH FLIGHT, AND PROVIDES THE PIC WITH ALTITUDE

INFORMATION OF THE UA ON THE HEADS­UP DISPLAY OF THE GCS.

4. EXTENT OF RELIEF ANDREW L. CHROSTOWSKI SEEKS AND THE

REASON ANDREW L. CHROSTOWSKI 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 15.5 MINUTES TO THE FIRST POINT

OF INTENDED LANDING AND, ASSUMING NORMAL CRUISING SPEED, TO

FLY AFTER THAT FOR AT LEAST 4.5 MINUTES. ANDREW L.

CHROSTOWSKI 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 ANDREW L. CHROSTOWSKI

PROPOSES TO CONDUCT PURSUANT TO THIS PETITION.

SIGNIFICANTLY, AS SET FORTH BELOW, THE TECHNICAL

SPECIFICATIONS OF THE DJI INSPIRE 1 UAS, THE DJI INSPIRE 1 UAS’S

OPERATING DOCUMENTS, AND PROPOSED OPERATING LIMITATIONS,

ENSURE THAT ANDREW L. CHROSTOWSKI WILL SAFELY OPERATE THE

BATTERY POWERED DJI INSPIRE 1 UAS DURING DAYLIGHT HOURS IN

VISUAL METEOROLOGICAL CONDITIONS (VMC), UNDER VISUAL

FLIGHT RULES (VFR), WITH ENOUGH BATTERY POWER TO FLY FOR A

TOTAL DURATION OF 15.5 MINUTES TO THE FIRST POINT OF INTENDED

LANDING AND, ASSUMING NORMAL CRUISING SPEED, TO FLY AFTER

THAT FOR AT LEAST 4.5 MINUTES.

5. EXTENT OF RELIEF ANDREW L. CHROSTOWSKI SEEKS AND THE

REASON ANDREW L. CHROSTOWSKI SEEKS RELIEF FROM

SECTIONS 91.405(A), 91.407(A)(1), 91.409(A)(1) & (A)(2), AND 91.4417(A)

& (B).

SINCE SECTIONS 91.405(A), 91.407(A)(1), 91.409(A)(1) & (A)(2),

AND 91.4417(A) & (B) ONLY APPLY TO AIRCRAFT WITH AN

AIRWORTHINESS CERTIFICATE, ANDREW L. CHROSTOWSKI REQUESTS
15

RELIEF FROM THESE SECTIONS BECAUSE THE DJI INSPIRE 1 UAS DOES

NOT REQUIRE AIRWORTHINESS CERTIFICATES. AS SET FORTH MORE

FULLY BELOW, THE DJI INSPIRE 1 UAS MEETS THE CONDITIONS OF

FMRA SECTION 333 FOR OPERATION WITHOUT AN AIRWORTHINESS

CERTIFICATE. ACCORDINGLY, ANDREW L. CHROSTOWSKI WILL USE

TRAINED TECHNICIANS TO PERFORM MAINTENANCE, ALTERATIONS,

OR PREVENTIVE MAINTENANCE ON THE UAS USING THE METHODS,

TECHNIQUES, AND PRACTICES PRESCRIBED IN THE UAS OPERATING

DOCUMENTS (I.E., ANDREW L. CHROSTOWSKI AERIAL OPERATIONS

MANUAL, MONTHLY MAINTENANCE LOG, DJI INSPIRE 1 INSTRUCTION

MANUAL, PRE­FLIGHT CHECKLIST). FURTHERMORE, ANDREW L.

CHROSTOWSKI WILL DOCUMENT AND MAINTAIN ALL MAINTENANCE

RECORDS FOR THE DJI INSPIRE 1 UAS.

C. THE REASONS WHY GRANTING ANDREW L. CHROSTOWSKI’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 ANDREW L. CHROSTOWSKI TO SAFELY,

EFFICIENTLY, AND ECONOMICALLY PERFORM AERIAL VIDEO AND

PHOTOGRAPHY OF CONSTRUCTION SITES, REAL ESTATE, AND

LANDSCAPE, BOATS, EVENTS, ECT. OVER CERTAIN AREAS OF THE

UNITED STATES.

ADDITIONALLY, USE OF THE DJI INSPIRE 1 UAS WILL DECREASE

CONGESTION OF THE NAS, REDUCE POLLUTION, CRASHES AND

ACCIDENTS CAUSED BY PILOT ERROR AND PROVIDE SIGNIFICANT

BENEFITS TO THE ECONOMY. NOTABLY, THE BENEFITS OF ANDREW L.

CHROSTOWSKI’S PROPOSED OPERATION OF THE DJI INSPIRE 1 UAS

WILL BE REALIZED WITHOUT IMPLICATING ANY PRIVACY ISSUES.

1. THE PUBLIC WILL BENEFIT FROM DECREASED

CONGESTION OF THE NAS.

THE DJI INSPIRE 1 UAS IS BATTERY POWERED AND

SERVES AS A SAFE, EFFICIENT, AND ECONOMICAL

ALTERNATIVE TO THE MANNED AIRCRAFT
16

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 DOES

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 PRODUCES 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 20­30

GALLONS PER HOUR OF LEADED AVIATION FUEL. THE

DJI INSPIRE 1 UAS, WHILE REDUCING THE CARBON

FOOTPRINT OF AERIAL ACQUISITIONS, ALSO ELIMINATES
17

NOISE POLLUTION, AS THE UAS IS 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 (WEIGHING

APPROXIMATELY 6 POUNDS 4 OUNCES AT ITS MAXIMUM

GROSS WEIGHT, WITH A LENGTH OF APPROXIMATELY 17

INCHES, WIDTH OF 17 INCHES, HEIGHT OF 11 INCHES, AND

WITH NO FUEL ON BOARD), HAS LESS PHYSICAL

POTENTIAL FOR COLLATERAL DAMAGE TO LIFE AND

PROPERTY ON THE GROUND, AND IN THE AIR, COMPARED

TO THE MANNED AIRCRAFT THAT TYPICALLY CONDUCT

SIMILAR OPERATIONS (WEIGHING APPROXIMATELY 6,000

POUNDS WITH A WINGSPAN OF APPROXIMATELY 42 FEET,

A LENGTH OF 34 FEET, AND 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 COMPANIES, LIKE ELITE A/V SOLUTIONS,

TO REMAIN COMPETITIVE AND CONTRIBUTE TO THE 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
18

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 ELITE A/V SOLUTIONS, 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,

ANDREW L. CHROSTOWSKI’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., ANDREW L.

CHROSTOWSKI AERIAL OPERATIONS MANUAL, MONTHLY

MAINTENANCE LOG, DJI INSPIRE 1 AND INSTRUCTION MANUAL,

PRE­FLIGHT CHECKLIST) 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.
19

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 ANDREW L. CHROSTOWSKI SEEKS

EXEMPTION.

1. REASONS WHY THE DJI INSPIRE 1 UAS MEETS 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, ANDREW L. CHROSTOWSKI’S OPERATION OF THE DJI

INSPIRE 1 UAS MEETS THE CONDITIONS OF FMRA SECTION 333, AND

WILL NOT REQUIRE AN AIRWORTHINESS CERTIFICATE IN

ACCORDANCE WITH 14 C.F.R. PART 21, SUBPART H. SECTION 333

PROVIDES AUTHORITY FOR A UAS TO OPERATE WITHOUT

AIRWORTHINESS CERTIFICATION AND SETS FORTH REQUIREMENTS

FOR CONSIDERING WHETHER A UAS WILL CREATE A HAZARD TO

USERS OF THE NAS OR THE PUBLIC, OR OTHERWISE POSE A THREAT

TO NATIONAL SECURITY. SPECIFICALLY, FMRA SECTION 333 STATES

THE FOLLOWING, IN PART:

(A)IN GENERAL ­­ NOTWITHSTANDING ANY OTHER

REQUIREMENT OF THIS SUBTITLE, AND NOT LATER THAN

180 DAYS AFTER THE DATE OF ENACTMENT OF THIS ACT,

THE SECRETARY OF TRANSPORTATION SHALL DETERMINE

IF CERTAIN UNMANNED AIRCRAFT SYSTEMS MAY

OPERATE SAFELY IN THE NATIONAL AIRSPACE SYSTEM

BEFORE COMPLETION OF THE PLAN AND RULEMAKING

REQUIRED BY SECTION 332 OF THIS ACT OR THE GUIDANCE

REQUIRED BY SECTION 334 OF THIS ACT.

(B) ASSESSMENT OF UNMANNED AIRCRAFT SYSTEMS ­­ IN

MAKING THE DETERMINATION UNDER SUBSECTION (A),

THE SECRETARY SHALL DETERMINE, AT A MINIMUM ­­

1) WHICH TYPES OF UNMANNED AIRCRAFT SYSTEMS, IF

ANY, AS A RESULT OF THEIR SIZE, WEIGHT, SPEED,

OPERATIONAL CAPABILITY, PROXIMITY TO

AIRPORTS AND POPULATED AREAS, AND OPERATION
20

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 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, ANDREW L.

CHROSTOWSKI 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.

A. THE SPECIFICATIONS OF THE DJI INSPIRE 1 UAS

DEMONSTRATES ITS SAFE CHARACTERISTICS.

THE DJI INSPIRE 1 UAS DOES 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 OF THE DJI

INSPIRE 1 UAS IS SET FORTH BY THE DJI

INSPIRE 1 SPECIFICATIONS AND DATA SHEET,
21

ATTACHED HERETO AS EXHIBIT 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 12, 44­51 OF THE DJI INSPIRE 1 USER

MANUAL, ATTACHED HERETO AS EXHIBIT B.

III. THE DJI INSPIRE 1 UAS IS DESIGNED FOR AUTOMATIC

RETURN TO HOME POINT OR HOVER IN THE EVENT

OF LOSS OF THE CONTROL LINK OR NAVIGATION.

WHEN THE CONTROL LINK IS LOST, THE DJI

INSPIRE 1 UAS WILL REMAIN STATIONARY, IN

FLIGHT, FOR 3 SECONDS OR MORE. IF, AFTER 3

SECONDS, THE DJI INSPIRE 1 UAS DOES NOT

REACQUIRE CONTROL LINK DATA FROM THE

GCS, THE UAS WILL ASSUME THAT THE

CONTROL LINK IS LOST AND THE UAS WILL

RETURN TO THE HOME POSITION AND

SHUTDOWN. A COMPLETE DESCRIPTION OF

THE FAILSAFE FUNCTIONS OF THE DJI INSPIRE

1 UAS ARE SET FORTH AT PAGE 60 OF THE DJI

INSPIRE 1 USER MANUAL, ATTACHED HERETO

AS EXHIBIT B.

IV. THE DJI INSPIRE 1 GCS AND ITS OPERATION.

A COMPLETE DESCRIPTION OF THE

OPERATION AND SPECIFICATIONS OF THE

DJI INSPIRE 1 GCS AND FLIGHT CONTROL

SOFTWARE IS PROVIDED AT PAGES 57 TO 62 OF

THE DJI INSPIRE 1 USER MANUAL. DJI INSPIRE

1 USER MANUAL IS ATTACHED HERETO AS

EXHIBIT B.

B. FLIGHT OPERATIONS OF DJI INSPIRE 1 UAS IS LIMITED TO THE
22

LINE OF SIGHT OF A CERTIFIED PILOT IN COMMAND WITH A

SAFETY OBSERVER.

ANDREW L. CHROSTOWSKI WILL ONLY UTILIZE

CERTIFICATED PILOTS WHO POSSESS A CURRENT AND VALID

AIRMAN MEDICAL CERTIFICATE TO ACT AS A PILOT IN

COMMAND (PIC) OF THE DJI INSPIRE 1 UAS. ADDITIONALLY, A

SAFETY OBSERVER WILL ASSIST ALL PILOTS DURING FLIGHT

TIME.

C. FLIGHTS OF DJI INSPIRE 1 UAS WILL BE CONDUCTED PURSUANT

TO SPECIFIC OPERATING LIMITATIONS.

IN SEEKING THIS EXEMPTION, ANDREW L. CHROSTOWSKI

PROPOSES TO COMMERCIALLY OPERATE THE DJI INSPIRE 1 UAS

FOR THE SPECIAL PURPOSE OF CONDUCTING AERIAL VIDEO AND

PHOTOGRAPHY OVER CERTAIN AREAS OF THE 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 UAS’ WEIGHING

LESS THAN 55 POUNDS MAXIMUM GROSS WEIGHT: DJI INSPIRE 1

UNMANNED AIRCRAFT SYSTEM. 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 UAS MUST BE OPERATED AT AN ALTITUDE OF NO MORE

THAN 500 FEET ABOVE GROUND LEVEL (AGL), AS INDICATED BY

THE PROCEDURES SPECIFIED IN THE OPERATING DOCUMENTS
23

UNLESS A SPECIAL REQUEST IS MADE AND APPROVED BY THE

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

FAA­ISSUED 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
24

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 (AFS­80) 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 PRE­FLIGHT 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.
25

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 UAS OPERATED UNDER THIS EXEMPTION MUST

COMPLY WITH ALL MANUFACTURER'S 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 THIRD­CLASS MEDICAL

CERTIFICATE.

18. THE OPERATOR MAY NOT PERMIT ANY PIC TO OPERATE

UNLESS THE PIC MEETS THE OPERATOR’S QUALIFICATION

CRITERIA AND DEMONSTRATES THE ABILITY TO SAFELY

OPERATE THE UAS IN A MANNER CONSISTENT WITH HOW THE

UAS WILL BE OPERATED UNDER THE EXEMPTION, INCLUDING

EVASIVE AND EMERGENCY MANEUVERS AND MAINTAINING

APPROPRIATE DISTANCES FROM PERSONS, VESSELS, VEHICLES

AND STRUCTURES. PIC QUALIFICATION FLIGHT HOURS MUST BE

LOGGED IN A MANNER CONSISTENT WITH 14 C.F.R. 61.51(B).

FLIGHTS FOR THE PURPOSES OF TRAINING THE OPERATOR’S

PICS ARE PERMITTED UNDER THE TERMS OF THE EXEMPTION.

HOWEVER, TRAINING OPERATIONS MAY ONLY BE CONDUCTED

DURING DEDICATED TRAINING SESSIONS. DURING TRAINING,

PROFICIENCY, AND EXPERIENCE­BUILDING FLIGHTS, ALL
26

PERSONS NOT ESSENTIAL FOR FLIGHT OPERATIONS ARE

CONSIDERED NONPARTICIPANTS, AND THE PIC MUST OPERATE

THE UAS WITH APPROPRIATE DISTANCE FROM

NONPARTICIPANTS IN ACCORDANCE WITH 14 C.F.R. 91.119.

19. UAS OPERATIONS MAY NOT BE CONDUCTED DURING THE

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 UAS 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 UAS 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 UAS LOSES COMMUNICATIONS OR LOSES ITS GPS

SIGNAL, IT MUST RETURN TO A PREDETERMINED LOCATION

WITHIN THE PLANNED OPERATING AREA AND LAND OR BE

RECOVERED IN ACCORDANCE WITH THE OPERATING

DOCUMENTS.

23. THE PIC MUST ABORT THE FLIGHT IN THE EVENT OF

UNPREDICTED OBSTACLES OR EMERGENCIES IN ACCORDANCE

WITH THE OPERATING DOCUMENTS.
27

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 UAS 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 (N­NUMBER) MARKINGS IN ACCORDANCE WITH

14 C.F.R. PART 45, SUBPART C. MARKINGS MUST BE AS LARGE AS

PRACTICABLE.

27. BEFORE CONDUCTING OPERATIONS, THE RADIO FREQUENCY

SPECTRUM USED FOR OPERATION AND CONTROL OF THE UA

MUST COMPLY WITH THE FEDERAL COMMUNICATIONS

COMMISSION (FCC) OR OTHER APPROPRIATE GOVERNMENT

OVERSIGHT AGENCY REQUIREMENTS.

28. THE DOCUMENTS REQUIRED FEWER THAN 14 C.F.R. 91.9 AND

91.203 MUST BE AVAILABLE TO THE PIC AT THE GROUND

CONTROL STATION OF THE UAS ANY TIME THE UAS IS

OPERATING. THESE DOCUMENTS MUST BE MADE AVAILABLE TO

THE ADMINISTRATOR OR ANY LAW ENFORCEMENT OFFICIAL

UPON REQUEST.
28

29. THE UA MUST REMAIN CLEAR AND YIELD THE RIGHT OF WAY

TO ALL MANNED AVIATION OPERATIONS AND ACTIVITIES AT

ALL TIMES.

30. THE UAS MAY NOT BE OPERATED BY THE PIC FROM ANY

MOVING DEVICE OR VEHICLE.

31. FLIGHT OPERATIONS MUST BE CONDUCTED AT LEAST 500

FEET FROM ALL NONPARTICIPATING PERSONS (PERSONS OTHER

THAN THE PIC, SO, OPERATOR TRAINEES OR ESSENTIAL

PERSONS), VESSELS, VEHICLES, AND STRUCTURES UNLESS:

A. BARRIERS OR STRUCTURES ARE PRESENT THAT

SUFFICIENTLY PROTECT NONPARTICIPATING PERSONS

FROM THE UA AND/OR DEBRIS IN THE EVENT OF AN

ACCIDENT. THE OPERATOR MUST ENSURE THAT

NONPARTICIPATING PERSONS REMAIN UNDER SUCH

PROTECTION. IF A SITUATION ARISES WHERE

NONPARTICIPATING PERSONS LEAVE SUCH PROTECTION

AND ARE WITHIN 500 FEET OF THE UA, FLIGHT

OPERATIONS MUST CEASE IMMEDIATELY AND/OR;

B. THE AIRCRAFT IS OPERATED NEAR VESSELS, VEHICLES OR

STRUCTURES WHERE THE OWNER/CONTROLLER OF SUCH

VESSELS, VEHICLES OR STRUCTURES HAS GRANTED

PERMISSION AND THE PIC HAS MADE A SAFETY

ASSESSMENT OF THE RISK OF OPERATING CLOSER TO

THOSE OBJECTS AND DETERMINED THAT IT DOES NOT

PRESENT AN UNDUE HAZARD, AND;

C. OPERATIONS NEARER TO THE PIC, SO, OPERATOR

TRAINEES OR ESSENTIAL PERSONS DO NOT PRESENT AN

UNDUE HAZARD TO THOSE PERSONS PER 91.119(A).

32.ALL OPERATIONS SHALL BE CONDUCTED OVER PRIVATE OR

CONTROLLED­ACCESS PROPERTY WITH PERMISSION FROM THE

LANDOWNER/CONTROLLER OR AUTHORIZED REPRESENTATIVE.

PERMISSION FROM LAND OWNER/CONTROLLER OR

AUTHORIZED REPRESENTATIVE WILL BE OBTAINED FOR EACH

FLIGHT TO BE CONDUCTED.
29

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

(AFS­80) 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.

ANDREW L. CHROSTOWSKI 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 FLIGHT­HOUR 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 ANDREW L. CHROSTOWSKI’S PROPOSED AREA OF

OPERATIONS, AND THE OPERATING LIMITATIONS SET FORTH­ABOVE;

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,

ANDREW L. CHROSTOWSKI SUBMITS THAT THE ADDITIONAL MANNED

AIRMANSHIP EXPERIENCE OF A COMMERCIALLY CERTIFICATED

PILOT WOULD NOT CORRELATE TO THE AIRMANSHIP SKILLS

NECESSARY FOR ANDREW L. CHROSTOWSKI’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). ANDREW
30

L. CHROSTOWSKI WILL NOT ALLOW ANY PIC TO OPERATE THE DJI

INSPIRE 1 UAS UNLESS THAT PIC HAS DEMONSTRATED, BY MEETING

MINIMUM FLIGHT­HOUR REQUIREMENTS AND 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 ANDREW L. CHROSTOWSKI’S

PROPOSED OPERATIONS. THE ADMINISTRATOR HAS HELD THAT

PRIOR DOCUMENTED FLIGHT EXPERIENCE THAT WAS OBTAINED IN

COMPLIANCE WITH APPLICABLE REGULATIONS WOULD ENSURE SAFE

OPERATIONS, STATING AS FOLLOWS:

IN EXEMPTION NO 11­62, 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

C.F.R. 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

MULTI­ROTOR 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
31

THE 10 HOURS OF MULTI­ROTOR TIME AND THE 10 HOURS MAY BE

INCLUDED IN THE TOTAL 25 HOURS OF UAD 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 EXPERIENCE­BUILDING FLIGHTS CAN

ALSO BE CONDUCTED UNDER THE GRANT OF EXEMPTION TO

ACCOMPLISH THE REQUIRED FLIGHT TIME. DURING TRAINING,

PROFICIENCY, AND EXPERIENCE­BUILDING 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, ANDREW L. CHROSTOWSKI WILL ENSURE SAFE

OPERATIONS BY NOT ALLOWING ANY PIC TO OPERATE THE DJI

INSPIRE 1 UAS UNLESS THAT PIC HAS DEMONSTRATED. BY MEETING

MINIMUM FLIGHT­HOUR 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.

CONCLUSION

ANDREW L. CHROSTOWSKI 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,
32

WHILE ALSO ADVANCING THE INTERESTS OF THE PUBLIC, BY

ALLOWING ANDREW L. CHROSTOWSKI TO SAFELY, EFFICIENTLY, AND

ECONOMICALLY OPERATE THE DJI INSPIRE 1 UAS COMMERCIALLY

WITHIN THE NAS. THEREFORE, IN ACCORDANCE WITH THE FEDERAL

AVIATION REGULATIONS AND THE FAA MODERNIZATION AND

REFORM ACT OF 2012, SECTION 333, ANDREW L. CHROSTOWSKI

RESPECTFULLY REQUESTS THAT THE ADMINISTRATOR GRANT THIS

PETITION FOR AN EXEMPTION FROM THE REQUIREMENTS OF 14 C.F.R.

SECTIONS 61.113 (A) AND (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 ELITE A/V

SOLUTIONS 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: 12/21/2015

SUBMITTED BY

ANDREW L. CHROSTOWSKI
33

​APPENDIX ­ A

DJI INSPIRE 1 TECHNICAL SPECIFICATIONS

ANDREW L. CHROSTOWSKI ONLY UTILIZES SAFE AND RELIABLE UAS’S.

DJI IS AN INDUSTRY LEADER IN SMALL UAS PRODUCTION. DJI UAS’S 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 REAL­TIME ALTITUDE AND LOCATION INFORMATION TO THE PIC

VIA THE LINKED MONITOR (SMART PHONE/TABLET DEVICES).

1.1 DJI INSPIRE 1

1.2 1.1.1 AIRCRAFT

1.1.1.1 SUPPORTED BATTERY ­ DJI 4500MAH LIPO BATTERY

1.1.1.2 WEIGHT (BATTERY & PROPELLERS INCLUDED) ­ 6.5LBS

103.529OZ (83,205G)

1.1.1.3 HOVER ACCURACY (READY TO FLY) ­ VERTICAL: 0.5M;

HORIZONTAL: 2.5M

1.1.1.5 MAX TILT ANGLE ­ 35 DEGREES

1.1.1.6 MAX ASCENT SPEED ­ 5 M/S

1.1.1.7 MAX DECENT SPEED ­ 4 M/S

1.1.1.8 MAX FLIGHT SPEED ­ 22 M/S (ATTI MODE, NO WIND, NOT

RECOMMENDED)

1.1.2 GIMBAL

1.1.2.1 WORKING CURRENT ­ STATIC: 750MA; DYNAMIC: 900MA

1.1.2.2 CONTROL ACCURACY ­ +/­.03 DEGREES

1.1.2.3 CONTROLLABLE RANGE ­ PITCH: ­90 DEGREES TO 30

DEGREES PAN: +/­ 320 DEGREES

1.1.2.4 MAXIMUM ANGULAR SPEED ­ PITCH: 120 DEGREES/S

PAN: 180 DEGREES/S

1.1.3 CAMERA

1.1.3.1 OPERATING TEMPERATURE RANGE ­ 0 TO 40 DEGREES C

1.1.3.2 SENSOR SIZE ­ 1 / 2.3”

1.1.3.3 EFFECTIVE PIXELS ­ 12.4M

1.1.3.4 RESOLUTION ­ 4000X3000

4.1.3.5 HD VIDEO RECORDING ­ UHD (4K): 4096X2160P24/25,

3840X2160P24/25/30
34

FHD: 1920X1080P24/25/30/48/50/60

HD: 1280X720P24/25/30/48/50/60

4.1.3.6 RECORDING FIELD OF VIEW ­ 94 DEGREES

APPENDIX ­ B

DJI INSPIRE 1 USER MANUAL

HTTP://WWW.DJI.COM/PRODUCT/INSPIRE­1/INFO#DOWNLOADS
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