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November 17, 2015

Daniel R. Cournoyer

Dba: Maine Drones

16 Fairview Drive

Lisbon, ME 04250

Danc16f@hotmail.com

207-577-7783

U. S. Department of Transportation

1200 New Jersey Avenue, SE

West Building, Ground Floor, Room W12-140

Washington, D.C. 20590

RE: Daniel R. Cournoyer’s Petition for Exemption from Federal Aviation Regulations for the 

purpose of operating an Unmanned Aircraft System.

Dear Sir or Madam,

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA) and 14 

C.F.R. Part 11, Daniel R. Cournoyer seeks an exemption from Federal Aviation Regulations to 

allow the commercial use of the DJI Inspire 1 Unmanned Aircraft System (UAS) to conduct aerial 

videography and photography of any business, construction site, real estate, landscapes,

structure inspections, and events within the National Airspace System (NAS).

Daniel R. Cournoyer has a Commercial Pilot License (ASEL) with an Instrument Rating and will 

be renewing his medical certificate in the very near future. Daniel R. Cournoyer has already 

applied to the FAA for a certificate of registration for his DJI Inspire 1 UAS. He also has 12 years 

of experience as a technician on Motion Pictures, TV shows and National Commercials. 
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Daniel R. Cournoyer seeks relief from the following Regulations:

 

14 CFR Part 21

14 CFR 45.23(b)

14 CFR 61.113(a) and (b)

14 CFR 91.7(a)

14 CFR 91.119(c)

14 CFR 91.121

14 CFR 91.151(a)(1)

14 CFR 91.405(a)

14 CFR 91.407(a)(1)

14 CFR 91.409(a)(1) and (2)

14 CFR 91.417(a) and (b)

Aircraft and Equivalent Level of Safety

The DJI Inspire 1 UAV will be operated by Daniel R. Cournoyer.

The operating limitations proposed by Daniel R. Cournoyer provide for at least an equivalent 

or higher level of safety than when using conventional passenger aircraft for videography and 

photography.

1. The UAS will weigh less than 55 lbs.

2. Flights will be operated within visual line of sight (VLOS) of a pilot and/or observer.

3. Prior to each flight the Pilot will conduct a Pre-flight Safety Inspection of the aircraft and will 

comply with all manufacturer safety bulletins.

4. Maximum flight time for each operational flight will be 18 minutes of less. Flights will be 

terminated at 30% battery power reserve.

5. Flights will be operated at an altitude of no more than 400 feet AGL and at a maximum 

speed of 49 mph.

6. Minimum crew for each flight will consist of the UAS Pilot who will be Pilot in Command 

(PIC) and a Visual Observer(VO).
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7. The UAS will operate within a confined sterile area with a set safety perimeter, the 

boundaries of which will be determined by UAS PIC based on the site specific activities and 

speed of the UAS required for the particular operation and coordinated with the 

jurisdictional FAA FSDO and local government officials as applicable.

8. A briefing will be conducted in regards to the planned UAS operations at the beginning of 

each day. It will be mandatory for all personnel performing duties within the boundaries of 

the safety perimeter be present at this briefing.

9. The UAS pilot will insure this safety perimeter by allowing only consenting personnel within 

close proximity of the UAS operation and not permitting anyone who has not been briefed 

or is not part of the production to be in the confined sterile area. 500 feet will be 

maintained from people not directly involved in the production.

10. The Pilot and VO will at all times be able to communicate by voice and/or two way radio.

11. Written and/or oral permission from the relevant property holders will be obtained.

12. If applicable, all required permissions and permits will be obtained from territorial, state, 

county, or city jurisdictions, including local law enforcement, fire, or other appropriate 

governmental agencies.

13. If the UAS loses communications or loses its GPS signal, the UAS has the capability to return 

to a predetermined location and land safely. The PIC will verify that the three safe modes 

(Return to Home, Failsafe, and Dynamic Home Point) on the Inspire 1 are functioning 

properly.

14. The PIC will abort the flight in case of emergencies or unforeseen obstacles.

15. The UAS will not be operated less than 500 feet below or less than 2000 feet horizontally 

from a cloud. Visibility must be at least 3 statute miles from the PIC.

16. No UAS flights will occur within 5 nautical miles of an airport unless prior permission is 

obtained from the local Flight Standards District Office.

17. The PIC must meet all flight review requirements and hold a current medical certificate.

18. The PIC must meet the minimum flight hour requirements in this particular UAS and 

demonstrate its safe operation.

Reasons why granting this exemption would be in the public interest.

The UAS will increase safety for the public because of its small size, less weight and lack of 

combustible fuel when compared to larger manned aircraft currently performing aerial 

photography, videography and/or data collection.

The public will benefit by a decrease in congestion of the NAS.

The public will benefit by a reduction in pollution because the UAS has electric motors.
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The public will benefit economically because it will be more cost effective for businesses to hire 

a UAS than a manned aircraft.

The public will benefit because there are no privacy issues. The UAS flights will only occur over 

private and/or controlled access property, with the landowner’s prior consent and knowledge.

Basis for Petition

14 CFR Part 21, Subpart H: Airworthiness Certificates

Given the size and limited operating area associated with the UAS to be utilized by Daniel R. 

Cournoyer, an Exemption from CFR 21 subpart H meets the requirements of an equivalent level 

of safety under Part 11 and section 333 of the Reform Act. The Federal Aviation Act 49 U.S.C. 

Section 44701 (f) and Section 333 of the Reform Act both authorize the FAA to exempt aircraft 

from the requirement of an airworthiness certificate, upon consideration of size, weight, speed, 

operational capability, and proximity to airports and populated areas of the particular UAS. In 

all cases, an analysis of these criteria demonstrates that the UAS operated without an 

airworthiness certificate, in the restricted environment and under the conditions proposed, will 

be at least as safe or safer than a conventional aircraft (fixed wing or rotorcraft) operating with 

an airworthiness certificate and without the conditions and restrictions proposed.

14 CFR 45.23(b) Display of Marks 

Because the DJI Inspire 1 does not have a cabin, cockpit or pilot station Daniel R. Cournoyer 

requests relief. The body of the aircraft will be marked with an N number as large as 

practicable.

14 CFR 61.113(a) and (b). Private pilot privileges and limitations: Pilot in Command

Daniel R. Cournoyer requests relief from Section 61.113(a) and (b) to the extent necessary to 

allow a person who holds a private pilot or higher level certificate, as well as a current and valid 

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

the UAS for compensation or hire. Daniel R. Cournoyer submits that an equivalent level of 

safety will be maintained because no PIC will be allowed to operate The DJI Inspire 1 UAS unless 

the PIC has met flight hour and currency requirements and demonstrates that he can safely 

operate the UAS in a manner consistent with operations specifications as described in this 
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exemption request. These include evasive and emergency maneuvers, as well as maintaining 

appropriate distances from people, vehicles, vessels and structures.

14 CFR 91.7(a) Civil Aircraft Airworthiness

Daniel R. Cournoyer seeks relief from Section 91.7(a) which states that “no person may operate 

a civil aircraft unless it is in an airworthy condition,” because the DJI Inspire 1 does not require 

an airworthiness certificate in accordance with CFR Part 21, Subpart H. Daniel R. Cournoyer 

submits the PIC will ensure the UAS is in condition for safe flight by determining that the UAS is 

in compliance with the DJI Inspire 1 Maintenance Manuel and a complete inspection of the 

aircraft and its systems is performed before each flight. A monthly Maintenance Log will be 

kept for the aircraft.

CFR 91.119(c) Minimum Safe Altitudes

Daniel R. Cournoyer seeks relief from Section 91.119 because operations conducted at 400 feet 

AGL or lower will require the UAS to be operated closer than 500 feet to essential persons or 

objects. An equivalent level of safety will be maintained because the UAS operates without 

people or fuel on board thus reducing the likelihood of death or serious bodily injury to persons 

in the air or on the ground, as well as reducing the risk of damage to vessels, vehicles and 

structures. Permission will be obtained from property owners and persons on the ground 

before operations.

14 CFR 121 Altimeter Settings

Daniel R. Cournoyer seeks relief from Section 121 because the UAS does not have a typical

barometric altimeter. An equivalent level of safety can be met because the altitude of the UAS 

is provided to the PIC through the aircraft’s GPS equipment and radio communications 

telemetry data link, which downlinks altitude information to the ground control system for 

active monitoring of the flight path. This information is sufficient for the PIC to maintain the 

UAS at an altitude below the 400 feet AGL limitation.

14 CFR 91.151(a)(1) Fuel Requirements for flight in VFR conditions. 

Daniel R. Cournoyer seeks relief from Section 91.151(a)(1) because the total flight time for the 

DJI Inspire 1 is 18 minutes maximum. An equivalent level of safety will be maintained because 

the UAS will terminate its flight when 30% of battery power remaining is reached.
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14 CFR 91.405(a), 91.407(a)(1), 91.409(a)(1)and (2), and 91.417(a) and (b)

Daniel R. Cournoyer seeks relief from sections 91.405(a), 91.407(a)(1), 91.409(a)(1) and (2), and 

91.417(a) and (b).

Since these Sections set forth requirements for maintenance that only apply to an aircraft with 

an airworthiness certificate. Daniel R. Cournoyer submits that the requested relief is proper 

since an equivalent level of safety will be ensured due to the following: Routine Maintenance, 

Preventative Maintenance and/or alterations to the UAS will be performed using the methods 

specified in the Manufacture’s Maintenance Manual. After any maintenance or alterations a 

functional flight test will be conducted before any further operations. Daniel R. Cournoyer will 

document and maintain all maintenance records on the UAS and will comply with all of the 

manufacturer’s safety bulletins.

Specifications of the DJI Inspire 1 UAS

Model: T600

Weight: 2935 g (Battery included) or 6lbs. 7.5 oz

Maximum speed: 49mph

Maximum flight time: 18minutes

Dimensions: 438x451x301 mm 

Motor: DJI 3510 (four total, electric)

The FAA has issued grants of exemption in circumstances similar to those presented in this 

petition (13428, 13302, 13309, 13439, and 13443).

Please find the User Manual, Quick Start Guide, Safety Guide, and Intelligent Flight Battery 

Guide for the DJI Inspire 1 aircraft:

www.dji.com/product/inspire-1/download

Respectfully, 

Daniel R. Cournoyer
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