UNITED STATES OF AMERICA

DEPARTMENT OF TRANSPORTATION

FEDERAL AVIATION ADMINISTRATION

WASHINGTON, DC

Regulatory Docket No.

IN THE MATTER OF THE PETITION FOR EXEMPTION OF:

Christopher Jared Ruxton

FOR AN EXEMPTION SEEKING RELIEF FROM THE REQUIR EMENTS 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

PURSU ANT TO SECTION 333 OF

THE FAA MODERNIZATION AND REFORM ACT OF 2012

(PUBLIC LAW 112

- 95)

Submitted on June 18

, 2015

Christopher Jared Ruxton

C.J. Ruxton LLC

166 N Township St

Sedro

- Woolley, WA 98284

360

- 708

- 21132 TABLE OF CONTENTS

Page

GLOSSARY OF ABBREVIATIONS.

................................ ................................ ................. 3

SUMMARY.

................................ ................................ ................................ ......................... 4

INTRODUCTION AND INTERESTS OF PETITIONER.

................................ ................... 4

BACKGROUND.

................................ ................................ ................................ .................. 5

BASIS FOR PETITION.

................................ ................................ ................................ ....... 5

NAME AND ADDRESS OF PETITIONER.

................................ ........................... 7

THE SPECIFIC SEC TIONS OF 14 C.F.R. FROM WHICH CHRISTOPHER

JARED RUXTON SEEKS EXEMPTION.

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

THE EXTENT OF RELIEF CHRISTOPHER JARED RUXTON SEEKS AND THE

REASON CHRISTOPHER JARED RUXTON SEEKS THE RELIEF............... 11

THE REASONS WHY GRANTING CHRISTOPHER JARED RUXTON’S

REQUEST W OULD BE IN THE PUBLIC INTEREST

.......... ........................... 15

THE REASONS WHY GRANTING THE EXEMPTION WOULD NOT

ADVERSELY AFFECT SAFETY.

................................ ................................ ........ 1 8

SUMMARY THAT CAN BE PUBLISHED IN THE FEDERAL REGISTER.

.... 3 3

ANY ADDITIONAL INFORMATION, VIEWS, OR ARGUMENTS

AVAILABLE TO SUPPORT CHRISTOPHER JARED RUXTON’S

REQUEST....

................................ ................................ ................................ ... 3 3

CONCLUSION.

................................ ................................ ................................ .................... 3 4

APPENDICES........................................................................................3 53 GLOSSARY OF ABBREVIATIONS

AGL Above Ground Level

AOI Area of Interest

ATC Air Traffic Control

ATO Air Traffic Organization

AV Aerial Ve hicle

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 t o Airman

PIC Pilot In Command

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

333 SO Safety Observer

SOP Standard Operating Procedures

UA Unmanned Aircraft

UAS Unmanned Aircraft System

VFR Visual Flight Rules

VLOS Visual Line of Site

VM C Visual Meteorological Conditions

VTOL Vertical Takeoff and Landing4 SUMMARY

Christopher Jared Ruxton 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

Christopher Jared Ruxton to operate an Unmanned Aircraft System (UAS) for the commercial

purp ose of conducting aerial video and photography of real estate, landscapes, and

commercial clients over certain areas of the United States.

INTRODUCTION AND INTERESTS OF THE PETITIONER

Christopher Jared Ruxton provides his clients with expertise and knowle dge in

photography and videography to increase efficiency, productivity and effectiveness.

Christopher Jared Ruxton has over 1 0 years of professional experience in photography and is

recognized as an expert in this area. The objective of Christopher Jared Ruxton aerial video

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

public, and residential uses, specifically targeting:

• Real

- estate marketing

• Commercial Filming

• Aerial acquisitions used for inspections of pub lic and private structures.

• Agricultural survey and land use.5 BACKGROUND

Unmanned Aircraft Systems: DJI Inspire 1 UASs

Christopher Jared Ruxton 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 6 pounds 7.5

ounces, a length of 17.3 inches, width of 17.7 inches, height of 11.8 inches, and a maximum

speed of approximately 42 knots. The DJI Inspire 1 UA is equipped with four main rotors;

driven by Lithium Polymer battery powered electric motors.

The DJI Inspire 1 UA that will be operated by Christopher Jared Ruxton 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, Christopher Jared Ruxton, 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 peti tions

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 opera tion, Christopher Jared Ruxton’s operation of the DJI

Inspire 1 UAS meets the conditions of FMRA Section 33 3 and therefore, will not require an6 airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H.

Accordingly, Christopher Jared Ruxton requests relief from Sections 91.405(a),

91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b), as thes e sections set forth

requirements for maintenance that only apply to aircraft with an airworthiness certificate.

Christopher Jared Ruxton submits that the requested relief is proper since an equivalent

level of safety will be ensured. Christopher Jared Rux ton will use experienced personnel or

technicians to perform maintenance, alterations, or preventive maintenance on the UAS using

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

Maintenance Log, and DJI Inspire 1 Instruction Manual). Furthermore, Christopher Jared

Ruxton 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: Pilo t in command , is requested by Christopher Jared Ruxton 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 fli ght

- 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.

Christopher Jared Ruxton seeks relief from Section 91.7(a), entitled Civil aircraft

airworthiness

, 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, Christoph er Jared Ruxton submits

that he will ensure that the DJI Inspire 1UAS is 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 Instruc tion Manual), and that the aircraft is in a

condition for safe flight.7 Christopher Jared Ruxton also seeks an exemption from the requirements of Section

91.121, entitled Altimeter Settings , as the DJI Inspire 1 UA will not have a typical barometric

altimet er onboard. However, altitude information of the DJI Inspire 1UA 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 fli ght path.

This altitude information, combined with Christopher Jared Ruxton’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, Christopher Ja red Ruxton seeks an exemption from the requirements of

Section 91.151(b), entitled Fuel requirements for flight in VFR conditions . Christopher Jared

Ruxton submits that safety will not be affected by operation of the DJI Inspire 1 UA during

daylight hours in visual meteorological conditions (VMC) under visual flight rules (VFR), with

enough battery power to fly for a total duration of approximately 13.5 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, Christopher Jared Ruxton 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 conta ct is:

Christopher Jared Ruxton

C.J. Ruxton LLC

166 N Township St

Sedro

- Woolley, WA 98284

360

- 708

- 2113

Email: cjruxton@gmail.com8 B. The Specific Sections Of 14 C.F.R. From Which Christopher Jared Ruxton

Seeks Exemption.

1. Christopher Jared Ruxton 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 pilo t 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. Christopher Jared Ruxton 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. Christopher Jared Ruxton Seeks Exemption From The Requirements Of

Section 91.121.

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

(a) Each person operating an aircraft shall maintain the cruising altitude or flig ht level

of that aircraft, as the case may be, by reference to an altimeter that is set, when

operating

--

(1) Below 18,000 feet MSL, to

--9 (i) The current reported altimeter setting of a station along the route and

within 100 nautical miles of the aircraft;

(ii) If t here is no station within the area prescribed in paragraph (a)(1)(i) of this

section, the current reported altimeter setting of an appropriate available

station; or

(iii) In the case of an aircraft not equipped with a radio, the elevation of the

departure airpo rt or an appropriate altimeter setting available before

departure.

4. Christopher Jared Ruxton 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 fo llowing:

(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 th at for at least 20 minutes.

5. Christopher Jared Ruxton 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 tha t 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. Christopher Jared Ruxton Seek s 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 undergo ne 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[.]10 7. Christopher Jared Ruxton 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 thi s chapter.

8. Christopher Jared Ruxton 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, progress ive, 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 A dministrator) 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.11 (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

requi red 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 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 a ction 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.

(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 s hall 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 Christopher Jared Ruxton Seeks And The Reason

Christopher Jared Ruxton Seeks The Relief.

1. Extent Of Relief Christopher Jared Ruxton And The Reason Christopher

Jared Ruxton 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.12 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 compen sation or

hire.

As set forth more fully below, Christopher Jared Ruxton 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 r equirements, demonstrating that

the 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.

Further, Christopher Jared Ruxton 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 Christopher

Jared Ruxton’s business; and (2) will not carry passengers or property for compensation or

hire.

2. Extent Of Relief Christopher Jared Ruxton Seeks And The Reason

Christopher Jared Ruxton Seeks Relief From Section 91.7(a).

Relief from Section 91.7(a) entitled Civil aircraf t airworthiness , is requested to the

extent required to allow Christopher Jared Ruxton 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., the Christopher Jared Ruxton Aerial Operations Manual, Monthly

Maintenance Log, and DJI Inspire 1 Instruction Manual).

Christopher Jared Ruxton seeks the requested relief because the DJI Inspire 1 UASs

does not require an airworthiness certificate in accordan ce with 14 C.F.R. Part 21, Subpart H.13 Therefore, Christopher Jared Ruxton 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 Christopher Jared Ruxton Seeks And The Reason

Christopher Jared Ruxton 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 t o 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), Christophe r Jared Ruxton seeks the requested relief because the DJI

Inspire 1 UA’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 UA is e quipped 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 Christopher Jared Ruxton Seeks and The Reason

Christopher Jared Ruxton 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 rules14 (VFR), for a total duration of 13.5 minutes to the first point of intended landing and, assuming

normal cruis ing speed, to fly after that for at least 4.5 minutes. Christopher Jared Ruxton seeks

the requested relief because without an exemption from Section 91.151(b), the flight time

duration of the battery powered DJI Inspire 1 UA will severely constrain the pra cticality of any

aerial video or still photo flight operations that Christopher Jared Ruxton 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 operatin g documents, and Christopher Jared Ruxton’s proposed operating

limitations, ensure that Christopher Jared Ruxton will safely operate the battery powered DJI

Inspire 1 UA during daylight hours in visual meteorological conditions (VMC), under visual

flight r ules (VFR), with enough battery power to fly for a total duration of 13.5 minutes to the

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

4.5 minutes.

5. Extent Of Relief Christopher Jared Ruxton Seeks And Th e Reason

Christopher Jared Ruxton 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 airworthine ss certificate, Christopher Jared Ruxton requests 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

operat ion without an airworthiness certificate. Accordingly, Christopher Jared Ruxton will use

trained technicians to perform maintenance, alterations, or preventive maintenance on the UAS

using the methods, techniques, and practices prescribed in the UAS operat ing documents (i.e.,

the Christopher Jared Ruxton Aerial Operations Manual, Monthly Maintenance Log, and DJI

Inspire 1 Instruction Manual). Furthermore, Christopher Jared Ruxton will document and

maintain all maintenance records for the DJI Inspire 1 UAS.15 D. The Reasons Why Granting Christopher Jared Ruxton 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 Christopher

Jared Ruxton to safely, efficiently, and economically perform aerial video and photography of

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 signific ant benefits to the economy. Notably, the benefits of Christopher

Jared Ruxton’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 Ins pire 1 UA is 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 al lowing

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 air craft operating in the NAS,

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

Inspire 1 UA does not require an airport to takeoff or land. Likewise, a reduction of manned

aircraft conducting aerial video and phot ography 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 pollution16 generated during traditional aerial video and still photography fligh t 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 20

- 30 gallons per hour of leaded aviation fuel. The DJI Inspire 1 UA,

while reducing the carbon footprint of aerial acquisitions, also eliminates noise pollution, as

the UAs are propell ed 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 tradit ional

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 its maximum gross weight with length

of 17.3 inches, width of 17.7 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 opera tions (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 UASs Will Benefit The Economy.

In addi tion 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 Christopher Jared

Ruxton’s, 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 ope rated17 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 Christopher Jared Ruxton’s,

can remain competitive and profitable, and therefore, provide greater job stabi lity 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 spendi ng; 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 flig ht operations that have been conducted for

decades, Christopher Jared Ruxton’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 documen ts (i.e., the Christopher Jared Ruxton Aerial Operations

Manual, Monthly Maintenance Log, and DJI Inspire 1 Instruction Manual) which requires

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

with the Federal Avia tion Regulations, including the minimum altitude requirements of 14

C.F.R. § 91.119.18 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 Christopher Jared Ruxton Seeks Exemption.

1. Reasons Why The DJI Inspire 1 UA 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 as sociated with

the unmanned aircraft and its operation, Christopher Jared Ruxton’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. Spe cifically, FMRA Section

333 states the following, in part:

(a) In General.

— Not withstanding 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 within visual line of sight do not create a hazard to

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

national security; and

(2) ) whether a certificate of waiver, certificate of authorization, or

airworthiness certificat ion 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 airc raft systems may operate safely in the

N

ational A irspace S ystem, the Secretary shall establish requirements for the safe

operation of such aircraft systems in the national airspace system.19 In seeking this exemption, Christopher Jared Ruxton 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

capabili ty.

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, attached hereto as Exhibit A

ii. The DJI Inspire 1 UAS Autonomous Flight And Navigati on 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 a t pages 12

- 16 and 45

- 50 of the DJI Inspire 1 User Manual, attached here to 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, t he DJI Inspire 1 UA will remain stationary, in flight,

for 3 seconds or more. If, after 3 seconds, the DJI Inspire 1 UA does not reacquire control

link data from the GCS, the UA will assume that the Control Link is lost and the UA will

return to the home p osition (i.e., failsafe mode) via GPS, and will descend to the takeoff

position and shutdown.

A complete description of the Failsafe Functions of the DJI Inspire 1 at pages 1320 through 15 of the User Manuals, attached hereto as Exhibit B.

iv. The DJI Inspire 1 G CS And I ts Operation.

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

and flight control software is provided at pages 40 through 47 of the DJI Inspire 1 User

Manual. DJI Inspire 1 User Manual is attached hereto as Exh ibits B.

b. Flight Operations Of DJI Inspire 1 UAS Is Limited To The Line Of Sight Of

A Certificated Pilot in Command With A Safety Observer.

Christopher Jared Ruxton will only utilize trained pilots to act as a pilot in command

(PIC) of the DJI Inspire 1 UA S. Additionally, a safety observer will assist all pilots during

flight time.

c. Flights Of DJI Inspire 1 UASs Will Be Conducted Pursuant To Specific

Operating Limitations.

In seeking this exemption, Christopher Jared Ruxton 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 fol lowing

aircraft described in the operating documents, rotorcraft UAS weighing less than 15

pounds maximum gross weight: DJI Inspire 1 Unmanned Aircraft Systems.

Proposed operations of any other aircraft will require a new petition or a petition to

amend th is grant.

2. UAS operations under this exemption will be limited to conducting operations for

the purpose of aerial video and photography.

3. The UAs may not be flown at an indicated airspeed exceeding 20 knots.

4. The UA must be operated at an altitude of no mo re 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 t he PIC or safety observer (SO) is not p ermitted.21 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 verball y 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 t he 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 ot her 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 gran t of exe mption

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 document s. 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 docume nts 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 t he 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. replace ment 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. Th e operator must carry out its maintenance, inspections, and record keeping22 requirements, in accordance with the operating documents. Maintenance, inspection,

alterations, and status of replacement/overhaul component parts must be noted in the

aircraft reco rds, 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 pe rson 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 oper ator 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 eme rgency 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

consid ered 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. §

19.1. All operations must be conducted under visual meteorological

conditions (VMC). If flight at night is required, a special request will be made at

the FAA office closest to proposed area of operations. Flights under special visual

flight rules (SVFR) are not authorized.

20. The UA may not operate wi thin 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 t he operator’s COA. The letter of

agreement with the airport management must be made available to the Administrator

upon request.

21. The UA may not be operated less than 500 feet below or less than 2,000 feet

horizontally from a cloud or when visibility is le ss than 3 statute miles from the PIC.

22. If the UA 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 and23 forecast weather conditions) there is enough power to fly at norm al cruising

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

remaining.

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

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

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 48hours

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 hav e

identification (N

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

Subpart C. Markings must be as large as practicable.

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

control of the UA must comply with the Feder al 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 operati ng. These documents must be made available to the

Administrator or any law enforcement official upon request.

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

operations and activities at all times.

30. The UAS may not be operated b y 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. Barri ers 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 nonpart icipating 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 ha s 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 pr esent an undue hazard to those persons per § 91.119(a).

32. All operations shall be conducted over private or controlled

- access property with24 permission from the land owner/controller or authorized representative.

Permission from land owner/controller or auth orized 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.

Christopher Jared Ruxton 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 operat e 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 mane uvers and maintaining

appropriate distances from people, vessels, vehicles and structures.

Considering Christopher Jared Ruxton’s proposed area of operations, and the operating

limitations set forth

- above; the parallel nature of private pilot aeronautical knowledge

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

airmanship skills necessary to safely operate the DJI Inspire 1 UAS, Christopher Jared Ruxton

submits that the additional manned airmanship experience of a commercially certificated pilot

would not correlate to the airmanship skills necessary for Christopher Jared Ruxton’s specific

proposed flight operations.

The FAA has previously granted relief from Section 61.113(a) and (b) specific to UAS,

in circumstance s 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).

Christopher Jared Ruxton will not al low any PIC to operate the DJI Inspire 1 UAS

unless that PIC has demonstrated, by meeting minimum flight

- hour requirements or the DJI25 Inspire 1 UAS training and currency requirements, that the PIC is able to safely operate the DJI

Inspire 1 UAS in a manne r 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 mus t

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 le vel of

safety during Christopher Jared Ruxton’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 Exempti on 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 rot orcraft 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 UA S 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 hour s 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 require ments 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 compliance26 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 f lights 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, Christopher Jared Ruxton will ensure safe operations by not allowing

any PIC to operate the DJI Inspi re 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 maint aining 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 maintain ed

because prior to every flight, Christopher Jared Ruxton will ensure that the 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, 1 1138, 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 from27 the UA to the GCS for active monitoring of the flight path and altitude. This altitude

inform ation, combined with Christopher Jared Ruxton’s operation of the DJI Inspire 1 UA

within visual line of sight, at or below 500 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 ma terial 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, Christopher Jared Ruxton will ensure that it will safely operate

the battery powered DJI Inspire 1 UA during daylight hours in VFR conditions, with enough

battery power to fly for a total duration of 13.5 minutes to the first point of intended landing

and, assuming normal cruising speed, to fly after that for at least 4.5 minutes.

Here, as in Exemption No. 11109, the technical specifications of the DJI Inspi re 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 pro vide audible28 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 ba ttery 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

limitat ions 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 91.1 51 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, 1115 8, 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, Christopher Jared Ruxton submits that th e 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 Christopher Jared Ruxton will use trained tec hnicians to perform maintenance,

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

practices prescribed in the operating documents (i.e., the Christopher Jared Ruxton Aerial

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

Furthermore, Christopher Jared Ruxton will document and maintain all maintenance records

for the DJI Inspire 1 UAS.30 Since the DJI Inspire 1 UAS will be inspected as prescribed by the operating

documents, Christopher Jar ed Ruxton will maintain the equivalent level of safety established

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

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

attached h ereto as Exhibit C.

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

Jared Ruxton will use trained technicians to perform maintenance, alterations or preventive

maintenance on the UAS using the methods, techniques, and pr actices 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 UASs will be performed by tr ained 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 Christopher Jared Ruxton’s proposed operating limitations, the

operating documents, and the technical aspects of the DJI Inspire 1 UAS, Christopher Jared

Ruxton 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 reli ef specific to UAS in circumstances similar, in all material

respects, to those presented herein (e.g. Exemption Nos. 11062, 11063, 11064,31 11065, 11066, 11067, 11080, 11109, 11110, 11112, 11136, 11138, 11150, 11153, 11156,

11157, 11158, 11159, 11160, 111 61).

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, Christopher Jared Ruxton requests

that the FAA pr escribe 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 ov er 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 purs uant to 14 C.F.R.

§ 21.16, for operation of the DJI Inspire 1 UASs, 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 unusu al design feature of the aircraft, aircraft engine or propeller,

he prescribes special conditions and amendments thereto for the product.32 The special conditions are issued in accordance with Part 11 of this chapter and

contain such safety standards for th e 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, Sub part H, and 14 C.F.R Sections

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

91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b).33 F. A Summary That Can Be Published In The Federal Register, stating: The Rules

From W hich Christopher Jared Ruxton Seeks Exemption:

Christopher Jared Ruxton 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 Des cription Of The Nature Of The Exemption Christopher Jared Ruxton

Seeks:

This exemption will permit Christopher Jared Ruxton to commercially operate an Unmanned Aircraft System (UAS) for the purpose of conducting aerial video and

photography over certain a reas of the United States.

G. Any Additional Information, Views, Or Arguments Available To Support

Christopher Jared Ruxton’s Request.

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

(FMRA) Section 333, which directs the Secre tary of Transportation to determine if certain

UAS may operate safely in the NAS. As such,

Christopher Jared Ruxton’s 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 pose a threat to national

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

certif ication.

As discussed in detail above, Christopher Jared Ruxton 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.34 CONCLUSION

As set fort h herein, Christopher Jared Ruxton 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 cert ificate, 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 20 12, while also advancing the interests of the

public, by allowing Christopher Jared Ruxton to safely, efficiently, and economically

operate the DJI Inspire 1 UAS commercially within the NAS.

WHEREFORE , in accordance with the Federal Aviation Regulations a nd the FAA

Modernization and Reform Act of 2012, Section 333, Christopher Jared Ruxton 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 t he United States.

Dated: June 18

, 2015

Respectfully submitted,

Christopher Jared Ruxton

Christopher Jared Ruxton

C.J. Ruxton LLC

166 N Township Street

Sedro

- Woolley, WA 98284

360

- 708

- 211335 Appendices :

A

– DJI Inspire 1 Specifications Data Sheet

B

– DJI Inspire 1 Manufacturer’ s User Manual

C

– Monthly Maintenance Log36 APPENDIX

– A

DJI INSPIRE 1 TECHNICAL SPECIFICATIONS

Christopher Jared Ruxton only utilizes safe and reliable UASs. DJI is an industry leader in

small UAS production. DJI UASs are loaded with ground breaking so ftware 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 a ddition, DJI software provides real

- time altitude and

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

2.2 DJI	Inspire	1

2.2.1 Aircraft

2.2.1.1 Model

– T600

2.2.1.2 Weight	(Battery	Included)

– 6lbs	7.5291oz	(2935g)

2.2.1.3 Hovering	Accuracy	(GPS	Mode)

– Vertical:	0.5m;	Horizontal:	2.5m

2.2.1.4 Max	Angular	Velocity

– Pitch:	3000/s;	Yaw: 1500/s

2.2.1.5 Max	Tilt	Angle

- 350

2.2.1.6 Max	Ascent	Speed

– 5m/s

2.2.1.7 Max	Descent	Speed

– 4m/s

2.2.1.8 Max	Speed

– 22m/s	(ATTI	mode,	no	wind

– NOT RECOMMENDED)

2.2.1.9 Max	Flight	Altitude

– 4500m

2.2.1.10 Max	Wind	Resistan ce

– 10m/s

2.2.1.11 Max	Flight	Time

– Approximately	18	minutes

2.2.1.12 Motor	Model

– DJI 3510

2.2.1.13 Propeller	Model

– DJI	1345

2.2.1.14 Operating	Temperature	Range

– 140F	to	1040F	(

- 100C	to 400C)

2.2.1.15 Dimensions

– 17	1⁄4”	x	17	3⁄4”	x 12”

2.2.2 Gimbal

2.2.2.1 Model

– ZENMUSE X3

2.2.2.2 Output	Power	(with	camera)

– Sta tic:	9W;	In	Motion: 11W

2.2.2.3 Operating	Current

– Static:	750mA;	In	Motion:	900mA

2.2.2.4 Angular	Vibration	Range

- ±0.030

2.2.2.5 Mounting

– Detachable

2.2.2.6 Controllable	Range

– Pitch:

- 900	to	+300;	Pan: ±3200

2.2.2.7 Mechanical	Range

– Pitch:

- 1250	to	450;	Pan:	±3300

2.2.2.8 Max	Controllable	Spee d

– Pitch:	1200/s;	Pan: 1800/s

2.2.3 Camera

2.2.3.1 Name

– X3

2.2.3.2 Model

– FC35037 2.2.3.3 Total	Pixels

– 12.76M

2.2.3.4 Effective	Pixels

– 12.4M

2.2.3.5 Image	Max	Size

– 4000x3000

2.2.3.6	ISO	Range

– 100

- 3200

2.2.3.7 Field	of	View

- 940

2.2.3.8 CMOS

– Sony	EXMOR 1/2.3”

2.2.3.9 HD	Video	Recording

– UHD(4K): 4096x2160p24/2 5,

3840x2160p24/25/30;	FHD:	1920x1080p24/25/30/48/50/60;	HD:

1280x720p24/25/30/48/50/60

2.2.3.10 Operating	Temperature	Range

- 320F

- 1040F	(00C

- 400C)

2.2.4 Transmitter

2.2.4.1 Name

– C1

2.2.4.2 Operating	Frequency

– 5.728

- 5.850GHz; 2.400

- 2.483GHz

2.2.4.3 Communicating	Distance	(unobstructed )

– 2000m

2.2.4.4 Output	Power

– 9W

2.2.4.5 Operating	Temperature	Range

- 140F	to	1040F	(

- 100C	to 400C)

2.2.4.6 Battery

– 600mAh	LiPo	2S38 APPENDIX

– B

DJI Inspire 1 Manufacturer’s User Manual

http://download.dji

innovations.com/downloads/inspire_1/en/Inspire_1_User_Manual_v1.2_en.pdf39 APPENDIX

– C

MONTHLY$MAINTENANCE$LOG

month: (year:

U AS$#:$ Date(Issue(

Discovered Date(Issue(

Addressed Issue(Description(&(Maintenance(Conducted Maintenance(Performed(By:(((

Print(&(Sign

Software(Updates

Airframe(

Engines

Propellers

Camera(Gimbal

Landing(Gear

Vibrati on(Dampening

Other: