UNITED STATES OF AMERICA 

DEPARTMENT OF TRANSPORTATION 

FEDERAL AVIATION ADMINISTRATION 

WASHINGTON, DC 

IN THE MATTER OF THE PETITION FOR EXEMPTION OF: 

Johnathon C. McClellan 

FOR AN EXEMPTION SEEKING RELIEF FROM THE REQUIREMENTS OF 

TITLE 14 OF THE CODE OF FEDERAL REGULATIONS 14 C.F.R §§ 61.23(a), 61.101(34) 61.113(a) & (b), 61.315 (a), 

91.7(a), 91.119 (c), 91.119 (c), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) &(a)(2), and 91.417(a) & (b), 

CONCERNING COMMERCIAL OPERATION OF DJI INSPIRE 1 UNMANNED AIRCRAFT SYSTEMS PURSUANT TO SECTION 

333 OF 

THE FAA MODERNIZATION AND REFORM ACT OF 2012 

(PUBLIC LAW 112-95) 

Submitted on February 16, 2016 

Johnathon C. McClellan 

3900 W 102 nd St 

Bloomington, MN 55437 

612-990-6900 
Table of Contents 

Table of Contents 2 

GLOSSARY OF ABBREVIATIONS 3 

SUMMARY 4 

INTRODUCTION AND INTERESTS OF THE PETITIONER 4 

BACKGROUND 4 

BASIS FOR PETITION 4 

Name And Address Of The Petitioner 5 

The Specific Sections Of 14 C.F.R. From Which Applicant Seeks Exemption 5 

The Extent Of Relief Applicant Seeks And The Reason Applicant Seeks The Relief 9 

The Reasons Why Granting Applicant Request Would Be In The Public Interest; That Is, How It Would Benefit The 

Public As A Whole 11 

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 Applicant Seeks 

Exemption 13 

CONCLUSION 22 

EXHIBIT A 23 

EXHIBIT C ATTACHED 

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GLOSSARY OF ABBREVIATIONS 

AGL Above Ground Level 

A01 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 

SO Safety Observer 

SOP Standard Operating Procedures 

UA Unmanned Aircraft 

UAS Unmanned Aircraft System 

VFR Visual Flight Rules 

VLOS Visual Line of Site 

VMC Visual Meteorological Conditions 

VTOL Vertical Takeoff and Landing 

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SUMMARY 

Johnathon C. McClellan (Applicant)seeks exemption from the requirements of 14 C.F.R §§ 61.23(a), 61.101(34) 

61.113(a) & (b), 61.315 (a),91.7(a),91.119 (c), 91.119 (c),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 Applicant to operate an Unmanned 

Aircraft System (UAS) for the commercial purpose of conducting aerial video and photography of to be used in 

television commercials, weather traffic and news reports, and sporting events over certain areas of the United States. 

INTRODUCTION AND INTERESTS OF THE PETITIONER 

My name is Johnathon C. McClellan, I am 37 years old Retired Minneapolis Fire Fighter. I am retired due to an injury 

in the line of duty, and now consult businesses. I am also an avid photographer with over 10 years' experience in all 

aspects of photography and see the need for new technology to improve quality, reduce costs, and help provide a 

new viewpoint from traditional photography. 

I wish to provide high quality imaging for a variety of commercial and public uses, specifically targeting: 

A) Aerial Surveying 

B) Commercial Photography 

C) Management of Construction Progress. 

D) Site Health and Safety Plan inspections 

E) Insure implementation of Environmental Controls such as storm water discharge requirements and pollution 

prevention mitigation. 

F) Inspections of Commercial Real Estate 

BACKGROUND 

Unmanned Aircraft Systems: DJI Inspire 1 UAS 

Applicant seeks an exemption to operate DJI systems for compensation or hire within the NAS. The DJI Inspire 1 are 

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 UAs are equipped with four main rotors; driven by Lithium Polymer battery powered electric motors. The 

DJI Inspire 1 UAs that will be operated by Applicant 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 

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Petitioner, Applicant, 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 UASs in the National Airspace System 

(NAS), and for an exemption from the requirements of 14 C.F.R §§ 61.23(a), 61.101(e4) 61.113(a) & (b), 61.315 

(a),91.7(a), 91.119 (c), 91.119 (c),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, Applicant operation of DJI Inspire 1 UASs meets the conditions of FMRA Section 333 and therefore, will 

not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. 

Accordingly, Applicant 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. 

Applicant submits that the requested relief is proper since an equivalent level of safety will be ensured. Applicant 

will use experienced personnel or technicians to perform maintenance, alterations, or preventive maintenance on 

the UASs using the methods, techniques, and practices prescribed in the operating documents. 

Relief from certain requirements of Section 61.113(a) and (b), entitled Private pilot privileges and limitations: Pilot in 

command, is requested by Applicant to the extent necessary to allow a Pilot in Command (PIC) holding a UAS, private 

pilot or higher level 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 UASs in a manner consistent with this 

exemption, including evasive and emergency maneuvers and maintaining appropriate distances from people, vessels, 

vehicles and structures. 

Applicant seeks relief from Section 91.7(a), entitled Civil aircraft airworthiness, because the DJI Inspire 1 UASs do not 

require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. As such, Applicant submits that 

he will ensure that the DJI Inspire 1UASs are in an airworthy condition, prior to every flight, by determining that the 

UASs are in compliance with the operating documents, and that the aircraft are in a condition for safe flight. 

Applicant also seeks an exemption from the requirements of Section 91.119 (c), entitled Minimum Safe Altitudes: 

General, as the DJI Inspire 1 UAs operate at low altitudes of 400 feet or less. 

Applicant also seeks an exemption from the requirements of Section 91.121, entitled Altimeter Settings, as the DJI 

Inspire 1 UAs will not have a typical barometric altimeter onboard. However, altitude information of the DJI Inspire 1 

UAs will be provided to the PIC via Global Positioning System (GPS) equipment and radio communications telemetry 

data link, which downlinks from the UA to the GCS for active monitoring of the flight path. This altitude information, 

combined with Applicant's operation of the DJI Inspire 1 UASs within visual line of sight, at or below 500 feet AGL, 

will ensure a level of safety equivalent to Section 91.121. 

Additionally, Applicant seeks an exemption from the requirements of Section 91.151(b), entitled Fuel requirements 

for flight in VFR conditions. Applicant 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 

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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, Applicant provides the following information in support of its petition for 

exemption: 

Name and Address Of The Petitioner. 

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

Johnathon C. McClellan 

3900 W 102 ndSt 

Bloomington, MN 55437 

612-990-6900 

Email: ghosttll@msn.com 

The Specific Sections Of 14 C.F.R. From Which Applicant Seeks Exemption. 

Applicant Seeks Exemption From The Requirements Of Section 61.23(a). Medical certificates: Requirement and 

duration. 

(a) Operations requiring a medical certificate. Except as provided in paragraphs (b) and (c) of this section. 

Applicant Seeks Exemption From The Requirements Of Section 61.101(e4) Recreational pilot privileges and 

limitations. 

(e)Except as provided in paragraphs (d) and (i) of this section, a recreational pilot may not act as pilot in command of 

an aircraft- 

(iv)With retractable landing gear; 

Applicant Seeks Exemption From The Requirements Of Section 61.113(a) And (b). 

Section 61.113, entitled Private pilot privileges and limitations: Pilot in command, subsections (a) and (b) prescribe 

the following, in relevant part: 

(a) No person who holds a private pilot certificate may act as a pilot in command (PIC) of an aircraft that is carrying 

passengers or property for compensation or hire; nor may that person, for compensation or hire, act as PIC of an 

aircraft. 

(b) A private pilot may, for compensation or hire, act as PIC of an aircraft in connection with any business or 

employment if— 

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

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

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Applicant Seeks Exemption From The Requirements Of Section 315 (a). 

61.315What are the privileges and limits of my sport pilot certificate? 

(a)If you hold a sport pilot certificate you may act as pilot in command of a light-sport aircraft, except as specified in 

paragraph (c) of this section. 

Applicant 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. 

Applicant Seeks Exemption From The Requirements Of Section 91.119 (c). 

Except when necessary for takeoff or landing, no person may operate an aircraft below the following altitudes: 

Applicant Seeks Exemption From The Requirements Of Section 91.121. 

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

(a) Each person operating an aircraft shall maintain the cruising altitude or flight level of that aircraft, as the case may 

be, by reference to an altimeter that is set, when operating- 

(1) Below 18,000 feet MSL, to- 

(i) The current reported altimeter setting of a station along the route and within 100 nautical miles of the aircraft; 

(ii) If there is no station within the area prescribed in paragraph (a)(1)(i) of this section, the current reported 

altimeter setting of an appropriate available station; or 

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

altimeter setting available before departure. 

Applicant Seeks Exemption From The Requirements Of Section 91.151(b). 

Section 91.151, entitled Fuel requirements for flight in VFR conditions, subsection (b), states the following: 

(b) No person may begin a flight in a rotorcraft under VFR conditions unless (considering wind and forecast weather 

conditions) there is enough fuel to fly to the first point of intended landing and, assuming normal cruising speed, to 

fly after that for at least 20 minutes. 

Applicant Seeks Exemption From The Requirement Of Section 91.405(a). 

Section 91.405, entitled Maintenance required, subsection (a), states the following: Each owner or operator of an 

aircraft- 
(a) Shall have that aircraft inspected as prescribed in subpart E of this part and shall between required inspections, 

except as provided in paragraph (c) of this section, have discrepancies repaired as prescribed in part 43 of this 

chapter[.] 

Applicant Seeks Exemption From The Requirements Of Section 91.407(a)(1) 

Section 91.407, entitled Operation after maintenance, preventive maintenance, rebuilding, or alteration, subsection 

(a)(1), states the following: 

(a) No person may operate any aircraft that has undergone maintenance, preventive maintenance, rebuilding, or 

alteration unless- 

(1) It has been approved for return to service by a person authorized under § 43.7 of this chapter[.] 

Applicant 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. 

Applicant Seeks Exemption From The Requirements Of Sections 91.417(a) And 91.417(b). 

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

(a) Except for work performed in accordance with §§ 91.411 and 91.413, each registered owner or operator shall 

keep the following records for the periods specified in paragraph (b) of this section: 

(1) Records of the maintenance, preventive maintenance, and alteration and records of the 100-hour, annual, 

progressive, and other required or approved inspections, as appropriate, for each aircraft (including the airframe) 

and each engine, propeller, rotor, and appliance of an aircraft. The records must include- 

(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. 

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(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 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. 

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

(1) The records specified in paragraph (a)(1) of this section shall be retained until the work is repeated or superseded 

by other work or for 1 year after the work is performed. 

(2) The records specified in paragraph (a)(2) of this section shall be retained and transferred with the aircraft at the 

time the aircraft is sold. 

(3) A list of defects furnished to a registered owner or operator under § 43.11 of this chapter shall be retained until 

the defects are repaired and the aircraft is approved for return to service. 

The Extent Of Relief Applicant Seeks And The Reason Applicant Seeks The Relief. 

Extent Of Relief Applicant Seeks And The Reason Applicant Seeks Relief From Section 61.23(a). 

Medical certificates: Requirement and duration. (a) Operations requiring a medical certificate. Except as provided in 

paragraphs (b) and (c) of this section. The PIC will not be operating a aircraft which is capable of carrying passengers 

or the pilot. 

Extent Of Relief ApplicantSeeks And The Reason ApplicantSeeksRelief From Section 61.101(e4). 

61.101 Recreational pilot privileges and limitations. (e)Except as provided in paragraphs (d) and (i) of this section, a 

recreational pilot may not act as pilot in command of an aircraft— (iv)With retractable landing gear; as the DJI 

Inspire 1 has retractable landing gear which is integral to the operation of the camera. The landing gear lifts to allow 

360 degree rotation of the camera without interference by the landing gear. This operation is ultimately safer than 

rotating the entire D1I Inspire 1 do the simplification of the rotation process. 

Extent Of Relief Applicant Seeks And The Reason Applicant Seeks Relief From Section 61.113(a) And (b). 

Relief from Section 61.113(a) and (b) entitled Private pilot privileges and limitations: Pilot in command, is requested 

to the extent necessary to allow a PIC holding a private pilot or higher level certificate, as well as a current and valid 

airman medical certificate, and who has met certain flight-hour and currency requirements, to conduct the proposed 

UAS flight operations for compensation or hire. This relief is requested since the limitations set forth in Section 

61.113(a) and (b) state that a private pilot may, for compensation or hire, act as PIC of an aircraft in connection with 

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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, Applicant submits that 

an equivalent level of safety will be maintained because no PIC will be allowed to operate the DJI Inspire 1 UAS unless 

that PIC has met certain flight-hour and currency requirements, demonstrating that the PIC is able to safely operate 

either the DJI Inspire 1 UAS in a manner consistent with the operations specifications as described in this exemption, 

including evasive and emergency maneuvers, as well as maintaining appropriate distances from people, vessels, 

vehicles and structures. 

Further, Applicant submits that all flights of the DJI Inspire 1 UASs, conducted by the PIC pursuant to the grant of this 

Petition: (1) will be incidental to Applicant's business; and (2) will not carry passengers or property for compensation 

or hire. 

Extent Of Relief Applicant Seeks And The Reason Applicant Seeks Relief From Section 91.7(a). 

Relief from Section 91.7(a) entitled Civil aircraft airworthiness, is requested to the extent required to allow Applicant 

to determine that the DJI Inspire 1 UASs are in airworthy condition prior to every flight by ensuring that the UAS is in 

compliance with the operating documents (i.e., the Applicant Aerial Operations Manual, Maintenance Log, and DJI 

Inspire 1 Instruction Manual). Applicant seeks the requested relief because the DJI Inspire 1 UASs do not require an 

airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. Therefore, Applicant will ensure that the 

DJI Inspire 1 UASs are in airworthy condition based upon its compliance with the operating documents prior to every 

flight, and further, determine that the aircraft are in condition for safe flight, as stated in the conditions and 

limitations below. 

Extent Of Relief Applicant Seeks And The Reason Applicant Seeks Relief From Section 91.119 (c). 

Relief from Section 91.119 (c), entitled Minimum Safe Altitudes: General, as the DJI Inspire 1 UAs operate at low 

altitudes of 400 feet or less. 

Extent Of Relief Applicant Seeks And The Reason Applicant 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 

UASs, which utilize a barometric pressure sensor, GPS equipment, and a radio communications telemetry data link to 

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

any altitude information concerning UAS operations be reported to air traffic control (ATC) in feet above ground level 

(AGL), Applicant 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 UAs are equipped with a barometric pressure sensor and GPS equipment, which 

automatically ensures that a ground level pressure setting will be established prior to each flight, and provides the 

PIC with altitude information of the UA on the heads-up display of the GCS. 

Extent Of Relief Applicant Seeks And The Reason Applicant Seeks Relief From Section 91.151(b). 

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Relief from Section 91.151(b) entitled Fuel requirements for flight in VFR conditions, is requested to the extent 

required to allow flights of the battery powered DJI Inspire 1 UAs during daylight hours in visual meteorological 

conditions (VMC), under visual flight rules (VFR), for a total duration of 13.5 minutes to the first point of intended 

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

proposes to conduct pursuant to this Petition. 

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

documents, and Applicant's proposed operating limitations, ensure that Applicant 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 of13.5 minutes to the first point of intended landing and, 

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

Extent Of Relief Applicant Seeks And The Reason Applicant Seeks Relief From Sections 91.405(a), 91.407(a)(1), 

91.409(a)(1) & (a)(2), And 91.417(a) & (b). 

Since Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) only apply to aircraft with an 

airworthiness certificate, Applicant requests relief from these Sections because the DJI Inspire 1 UASs do not require 

airworthiness certificates. As set forth more fully below, the DJI Inspire 1 UASs meet the conditions of FMRA Section 

333 for operation without an airworthiness certificate. Accordingly, Applicant will use trained technicians to perform 

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

prescribed in the UAS operating documents (i.e., the Applicant Aerial Operations Manual, and DJI Inspire 1 

Instruction Manual). 

The Reasons Why Granting Applicant 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 Applicant to safely, efficiently, and 

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

areas of the United States. 

Additionally, use of the DJI Inspire 1 UAS's will decrease congestion of the NAS, reduce pollution, and provide 

significant benefits to the economy. Notably, the benefits of Applicant's proposed operation of the DJI Inspire 1 

UAS's will be realized without implicating any privacy issues. 

The Public Will Benefit From Decreased Congestion Of The NAS. 

The DJI Inspire 1 UAs are battery powered and serve as a safe, efficient, and economical alternative to the manned 

aircraft 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. 

11 I Page 
Furthermore, by reducing the number of manned aircraft operating in the NAS, congestion around airports caused by 

arriving and departing aircraft will be reduced. The DJI Inspire 1 UAs do not require an airport to takeoff or land. 

Likewise, a reduction of manned aircraft conducting aerial video and photography missions would result in fewer 

aircraft that must be handled by air traffic control during the ground, takeoff, departure, arrival, and landing phases 

of flight operations. 

The Public Will Benefit From The Safety And Efficiency Of The DJI Inspire 1 UASs. 

Conducting aerial acquisitions with the DJI Inspire 1 UASs, 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 UASs produce no air 

pollution, and is the most viable environmentally conscious alternative to the cabin class, six cylinder internal 

combustion engine aircraft that are typically utilized for aerial video and photography, while burning approximately 

20-30 gallons per hour of leaded aviation fuel. The DJI Inspire 1 UAs, while reducing the carbon footprint of aerial 

acquisitions, also eliminates noise pollution, as the UAs are propelled by battery powered electric motors, rather 

than an internal combustion engine. 

By using the DJI Inspire 1 UASs 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 all 

Inspire 1 UAs (weighing approximately 6 pounds 7.5 ounces respectively, at maximum gross weights with lengths of 

16 inches and 17.7 inches respectively, and with no fuel on board), has less physical potential for collateral damage 

to life and property on the ground, and in the air, compared to the manned aircraft that typically conduct similar 

operations (weighing approximately 6,000 pounds with a wingspan of approximately 42 feet, a length of 34 feet, and 

a fuel capacity of 180 gallons). 

Performing Aerial Video and Photography Operations With The 3DR Soloand DJI Inspire 1 UASs Will Benefit The 

Economy. 

In addition to being safe and efficient, the DJI Inspire 1 UASs are also an economical alternative to using manned 

aircraft to conduct similar aerial operations. As such, operation of the DJI Inspire 1 UASs will allow United States 

based companies, like Applicant, to remain competitive and contribute to growth of the U.S. economy. Specifically, 

with the rising cost of aviation fuel and the Environmental Protection Agency ("EPA") regulatory actions phasing out 

leaded aviation fuels, U.S. owned and operated companies must adopt new and alternative technology in order to 

remain competitive. Operating the battery powered DJI Inspire 1 UASs 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 UASs, companies such as Applicant, 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 

UASs, 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. 

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There Are No Privacy Issues. 

Similar to the manned aerial acquisition flight operations that have been conducted for decades, Applicant's 

proposed operation of the DJI Inspire 1 UASs will not implicate any privacy issues. Specifically, the DJI Inspire 1 UASs 

will be operated only in compliance with operating documents (i.e., the Applicant Aerial Operations Manual, and DJI 

Inspire 1 Instruction Manual) which requires property owner involvement, and in accordance with the Federal 

Aviation Regulations, including the minimum altitude requirements of 14 C.F.R. § 91.119. 

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 Applicant Seeks Exemption. 

Reasons Why The DJI Inspire 1 UAs Meet The Conditions Of The FAA Modernization and Reform Act of 2012 

(FMRA) Section 333. 

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

operation, Applicant's operation of the DJI Inspire 1 UASs meet the conditions of FMRA Section 333, and will not 

require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. 

Section 333 provides authority for a UAS to operate without airworthiness certification and sets forth requirements 

for considering whether a UAS will create a hazard to users of the NAS or the public, or otherwise pose a threat to 

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

(a) In General.--Notwithstanding any other requirement of this subtitle, and not later than 180 days after the date of 

enactment of this Act, the Secretary of Transportation shall determine if certain unmanned aircraft systems may 

operate safely in the national airspace system before completion of the plan and rulemaking required by section 332 

of this Act or the guidance required by section 334 of this Act. 

(b) Assessment of Unmanned Aircraft Systems.--In making the determination under subsection (a), the Secretary 

shall determine, at a minimum- 

(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 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, Applicant submits that the DJI Inspire 1 UASs can operate safely in the NAS pursuant to 

FMRA Section 333, as demonstrated by: (a) the characteristics of the DJI Inspire 1 UASs; (b) the pilot certification 

requirement; and (c) the specific operating limitations. 

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

The DJI Inspire 1 UASs do not create a hazard to users of the NAS or the public, or otherwise pose a threat to national 

security considering its size, weight, speed, and operational capability. 

i. Technical Specifications Of The DJI Inspire 1 UASs. 

The technical specifications of the 3DR SoloandDJl Inspire 1 UASs are set forth by the 3DR Solo and DJI Inspire 1 

Specifications and Data Sheet, attached hereto as Exhibit A. 

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

Operational Area. 

DJI Inspire 1 UASs 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 UASs is provided at pages pages 12-16 and 45-50 of the DJI Inspire 1 

User Manuals, attached hereto as Exhibit C. 

iii. The DJI Inspire 1 UASs Are Designed For Automatic Return To Home Point Or Hover In The Event Of Loss Of The 

Control Link Or Navigation. 

When the Control Link is lost, the DJI Inspire 1 UAs will remain stationary, in flight, for 3 seconds or more. If, after 3 

seconds, the DJI Inspire 1 UAs do not reacquire control link data from the GCS, the UAs will assume that the Control 

Link is lost and the UAs will return to the home position (i.e., failsafe mode) via GPS, and will descend to the takeoff 

position and shutdown. A complete description of the Failsafe Functions of the DJI Inspire 1 at pages 13 through 15 

of the DJI Inspire 1 User Manuals, attached hereto as Exhibit C. 

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 40 through 47 of the DJI Inspire 1 User Manual. DJI Inspire 1 User Manual are attached hereto as 

Exhibits C. 

b. Flight Operations Of 3DR Soloand DJI Inspire 1 UASs Are Limited To The Line Of Sight Of A Certificated Pilot in 

Command With A Safety Observer. 

Applicant will only utilize certificated pilots who possess a current and valid airman medical certificate to act as a 

pilot in command (PIC) of the Inspire 1 UASs. 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, Applicant proposes to commercially operate DJI Inspire 1 UASs for the special purpose of 

conducting aerial video and photography over certain areas of United States, pursuant to the following specific 

operating limitations: 

1. Operations authorized by this grant of exemption will be limited to the following aircraft described in the operating 

documents, rotorcraft UASs weighing less than 55 pounds maximum gross weight: DJI Inspire 1 Unmanned Aircraft 

Systems. Proposed operations of any other aircraft will require a new petition or a petition to amend this grant. 

14 I P P ' 
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 more than 500 feet above ground level (AGL), as indicated by the 

procedures specified in the operating documents unless a special request is made and approved by ATC. All altitudes 

reported to ATC must be in feet AGL. 

5. The UAs must be operated within visual line of sight (VLOS) of the PIC at all times. This requires the PIC to be able 

to use human vision unaided by any device other than corrective lenses, as specified on the PIC's FAA-issued airman 

medical certificate. 

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

7. All operations must utilize a safety observer (SO). The SO may be used to satisfy the VLOS requirement as long as 

the PIC always maintains VLOS capability. The SO and PIC must be able to communicate verbally at all times. 

Electronic messaging or texting is not permitted during flight operations. The PIC must be designated before the 

flight and cannot transfer his or her designation for the duration of the flight. The PIC must ensure that the SO can 

perform the functions prescribed in the operating documents. 

8. The SO must not perform any other duties beyond assisting the PIC with seeing and avoiding other air traffic and 

other ground based obstacles/obstructions and is not permitted to operate the camera or other instruments. 

9. The operating documents and the grant of exemption must be accessible during UAS operations and made 

available to the Administrator upon request. If a discrepancy exists between the conditions and limitations contained 

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

contained in the grant of exemption take precedence and must be followed. Otherwise, the operator must follow the 

procedures as outlined in its operating documents. The operator may update or revise its operating documents. It is 

the operator's responsibility to track such revisions and present updated and revised documents to the Administrator 

upon request. The operator must also present updated and revised documents if it petitions for extension or 

amendment to the grant of exemption. If the operator determines that any update or revision would affect the basis 

upon which the FAA granted the exemption, then the operator must petition for amendment to its grant of 

exemption. The FAA's UAS Integration Office (AFS-80) may be contacted if questions arise regarding updates or 

revisions to the operating documents. 

10. Prior to each flight the PIC must inspect the UAS to ensure that it is in a condition for safe flight. If the inspection 

reveals a condition that affects the safe operation of the UAS, the aircraft is prohibited from operating until the 

necessary maintenance has been performed and the UAS is found to be in a condition for safe flight. The Ground 

Control Station must be included in the preflight inspection. All maintenance and alterations must be properly 

documented in the aircraft records. 

11. Any UAS that has undergone maintenance or alterations that affect the UAS operation or flight characteristics, 

e.g. replacement of a flight critical component, must undergo a functional test flight. The PIC who conducts the 

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

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

equipment, not already covered in the relevant sections of the operating documents. 

13. The operator must follow the UAS manufacturer's aircraft/component, maintenance, overhaul, replacement, 

inspection, and life limit requirements. 

14. The operator must carry out its maintenance, inspections, and record keeping requirements, in accordance with 

the operating documents. Maintenance, inspection, alterations, and status of replacement/overhaul component 

parts must be noted in the aircraft records, including total time in service, description of work accomplished, and the 

signature of the authorized person returning the UAS to service. 

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

16. The authorized person must make an entry in the aircraft record of the corrective action taken against 

discrepancies discovered between inspections. 

17. The PIC must possess at least a private pilot certificate and at least a current third-class medical certificate. 

18. The operator may not permit any PIC to operate unless the PIC meets the operator's qualification criteria and 

demonstrates the ability to safely operate the UAS in a manner consistent with how the UAS will be operated under 

the exemption, including evasive and emergency maneuvers and maintaining appropriate distances from persons, 

vessels, vehicles and structures. PIC qualification flight hours must be logged in a manner consistent with 14 C.F.R. § 

61.51(b). Flights for the purposes of training the operator's PICs are permitted under the terms of the exemption. 

However, training operations may only be conducted during dedicated training sessions. During training, proficiency, 

and experience-building flights, all persons not essential for flight operations are considered nonparticipants, and the 

PIC must operate the UA with appropriate distance from nonparticipants in accordance with 14 C.F.R. § 91.119. 

19. UAS operations may not be conducted during night, as defined in 14 C.F.R. § 1.1. All operations must be 

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

at the FAA office closest to proposed area of operations. Flights under special visual flight rules (SVFR) are not 

authorized. 

20. The UA may not operate within 5 nautical miles of an airport reference point as denoted on a current FAApublished aeronautical chart unless a letter of agreement with that airport's management is obtained, and the 

operation is conducted in accordance with a NOTAM as required by the operator's COA. The letter of agreement with 

the airport management must be made available to the Administrator upon request. 

21. The UA may not be operated less than 500 feet below or less than 2,000 feet horizontally from a cloud or when 

visibility is less than 3 statute miles from the PIC. 

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. 

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24. The PIC is prohibited from beginning a flight unless (considering wind and forecast weather conditions) there is 

enough power to fly at normal cruising speed to the intended landing point and land the UA with 25% battery power 

remaining. 

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

prior to conducting any operations under the grant of exemption. This COA will also require the operator to request a 

Notice to Airman (NOTAM) not more than 72 hours in advance, but not less than 48 hours prior to the operation. All 

operations shall be conducted in accordance with airspace requirements in the ATO issued COA including class of 

airspace, altitude level and potential transponder requirements. 

26. All aircraft operated in accordance with the exemption must be identified by serial number, registered in 

accordance with 14 C.F.R. part 47, and have identification (N-Number) markings in accordance with 14 C.F.R. part 45, 

Subpart C. Markings must be as large as practicable. 

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

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 controlled-access property with permission from the land 

owner/controller or authorized representative. Permission from land owner/controller or authorized representative 

will be obtained for each flight to be conducted. 

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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 . 

Reasons Why An Exemption From The Requirements Of Section 61.113(a) And (b) Would Not Adversely Affect 

Safety. Applicant 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 UASs unless that PIC has demonstrated, by 

meeting minimum flight-hour and currency requirements, that the PIC is able to safely operate ther 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 Applicant'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, Applicant submits 

that the additional manned airmanship experience of a commercially certificated pilot would not correlate to the 

airmanship skills necessary for Applicant'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). 

Applicant will not allow any PIC to operate the DJI Inspire 1 UAS unless that PIC has demonstrated, by meeting 

minimum flight-hour requirements or the DJI Inspire 1 UAS training and currency requirements, that the PIC is able to 

safely operate the DJI Inspire 1 UAS in a manner consistent with this exemption, including evasive and emergency 

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

Specifically, the PIC must have accumulated and logged, in a manner consistent with 14 C.F.R. § 61.51(b), 25 hours of 

total time as a UAS rotorcraft pilot (with a minimum of 5 hours of those hours as a UAS pilot operating the same 

make and model of UAS to be used for operations under the exemption). In addition to the hour requirements, the 

PIC must accomplish 3 takeoffs and landings in the preceding 90 days (for currency purposes). As in Exemption Nos. 

11062, 11138, and 11153, prior documented flight experience that was obtained in compliance with applicable 

regulations will ensure an equivalent level of safety during Applicant'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. 11062, the FAA required that prior to conducting operations for the purpose of motion picture 

filming (or similar operations), the PIC must have accumulated and logged, in a manner consistent with 14 CFR 

61.51(b), 25 hours of total time as a UAS rotorcraft pilot including at least 10 hours logged as a UAS pilot with a 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 the 10 hours of multi-rotor time and the 10 hours may 

be included in the total 25 hours of UAS rotorcraft time. In addition to the hour requirements, the PIC must 

18IPage 
accomplish 3 takeoffs and landings in the preceding 90 days (for currency purposes). The FAA finds that at a 

minimum, the flight-hour requirements in Exemption No. 11062 are appropriate to practice and build proficiency in 

the skills necessary to safely conduct the petitioner's proposed operations. The FAA also finds that prior documented 

flight experience that was obtained in compliance with applicable regulations would satisfy this requirement. 

Training, proficiency, and experience-building flights can also be conducted under the grant of exemption to 

accomplish the required flight time. During training, proficiency, and experience-building flights the PIC is required to 

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

Exemption No. 11138 at page 15. 

Accordingly, Applicant will ensure safe operations by not allowing any PIC to operate the DJI Inspire 1 UAS unless that 

PIC has demonstrated, by meeting minimum flight-hour and currency requirements, that the PIC is able to safely 

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

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

Reasons Why An Exemption From The Requirements Of Section 91.7(a) Would Not Adversely Affect Safety. 

The equivalent level of safety established by Section 91.7(a) will be maintained because prior to every flight, 

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

Reasons Why An Exemption From The Requirements Of Section 91.119 (c) and91.121 Would Not Adversely Affect 

Safety. 

The equivalent level of safety established by Sections 91.119 (c) and91.121 will be maintained because the altitude 

information of the DJI Inspire 1 UAs will be provided to the PIC via GPS equipment and a radio communications 

telemetry data link, which downlinks from the UA to the GCS for active monitoring of the flight path and altitude. 

This altitude information, combined with Applicant'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. The altitude information will be 

generated by GPS equipment installed onboard the aircraft. Prior to each flight, a zero altitude initiation point is 

automatically established by the UASs at ground level. 

The FAA has previously granted relief from Section 91.121 specific to UAS, in circumstances similar, in all material 

respects, to those presented herein (e.g. Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 

11112, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161). 

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 UASs; (2) the limitations on the proposed flight 

operations; and (3) the location of the proposed flight operations. Accordingly, Applicant will ensure that it will safely 

19 I 
operate the battery powered DJI Inspire 1 UAs during daylight hours in VFR conditions, with enough battery power to 

fly for a total duration of 13.5 minutes to the first point of intended landing and, assuming normal cruising speed, to 

fly after that for at least 4.5 minutes. 

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

audible and visual warnings to the PIC at the GCS when the UAs experiences low battery voltage, the first warning 

occurring at approximately 33% remaining battery power, and again at approximately 10% remaining battery power. 

At the critically low battery level, the DJI Phantom Vision+ and DJI Inspire 1 UASs will descend and land automatically. 

Significantly, previous exemptions granted by the FAA concerning Section 91.151 establish that safety is not 

adversely affected when the technical characteristics and operating limitations of the UAS are considered. Relief has 

been granted for manned aircraft to operate at less than the minimums prescribed in Section 91.151, including 

Exemption Nos. 2689, 5745, and 10650. Moreover, the FAA has previously granted relief from Section 91.151 specific 

to UAS, in circumstances similar, in all material respects, to those presented herein (e.g. Exemption Nos. 8811, 

10808, 10673, 11042, 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11136, 11138, 11150, 

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

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, Applicant submits that the equivalent level of safety with regard to the regulatory maintenance and 

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

be met because Applicant will use trained technicians to perform maintenance, alterations, or preventive 

maintenance on the UASs using the methods, techniques, and practices prescribed in the operating documents (i.e., 

the Applicant Aerial Operations Manual, and DJI Inspire 1 Instruction Manual). 

Since the DJI Inspire 1 UASs will be inspected as prescribed by the operating documents, Applicant 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 are attached hereto as Exhibit C; a copy of the DJI Inspire 1 UAS. 

Likewise, the exemption sought will not adversely affect safety because Applicant will use trained technicians to 

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

practices prescribed by the operating documents. 

Furthermore, the exemption sought would maintain an equivalent level of safety established by Sections 91.407, 

91.417(a) and 91.417(b), because all maintenance of the DJI Inspire 1 UASs will be performed by trained technicians. 

Maintenance will be documented and maintained utilizing the monthly maintenance log. 

Significantly, previous exemptions granted by the FAA concerning Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & 

(a)(2), and 91.417(a) & (b) establish that safety is not adversely affected when the technical characteristics and 

operating limitations of the UAS are considered. 

20 IPage 
In consideration of Applicant's proposed operating limitations, the operating documents, and the technical aspects of 

the DJI Inspire 1 UASs, Applicant submits that safety will not be adversely affected by granting exemption from 14 

C.F.R. Sections 91.405(a), 91.407(a)(1) and (a)(2), 91.409(a)(2), and 91.417(a) and (b). The FAA has previously granted 

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

11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112, 11136, 11138, 11150, 11153, 11156, 

11157, 11158, 11159, 11160, 11161). 

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, Applicant requests that the FAA prescribe special conditions for the intended operation 

of the D11 Inspire 1 UASs, which contain such safety standards that the Administrator finds necessary to establish a 

level of safety equivalent to that established by 14 C.F.R. Part 21, Subpart H, and 14 C.F.R §§ 61.113(a) & (b), 91.7 (a), 

91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b). Such special conditions will 

permit safe operation of the UAs for the limited purpose of conducting aerial video and photography over certain 

areas of the United States for compensation or hire. FMRA Section 333 sets forth the requirements for considering 

whether a UAS will create a hazard to users of the NAS or the public, or otherwise pose a threat to national security; 

and further, provides the authority for such UAS to operate without airworthiness certification in accordance with 

any requirements that must be established for the safe operation of the UAS in the NAS. 

Likewise, the Administrator may prescribe special conditions pursuant to 14 C.F.R. § 21.16, for operation of the DJI 

Inspire 1 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 unusual design feature of the aircraft, 

aircraft engine or propeller, he prescribes special conditions and amendments thereto for the product. The special 

conditions are issued in accordance with Part 11 of this chapter and contain such safety standards for the aircraft, 

aircraft engine or propeller as the FAA finds necessary to establish a level of safety equivalent to that established in 

the regulations. 

See 14 C.F.R. § 21.16. 

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

the Applicant intended operation of the D11 Inspire 1 UASs, which contain such safety standards that the 

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

H, and 14 C.F.R Sections 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 

91.417(a) & (b). 

A Summary That Can Be Published In The Federal Register, stating: The Rules From Which ApplicantSeeks 

Exemption: 

21IPage 
od1 

athon C. McClellan 

900 W 102 nd St 

Bloomington, MN 55437 

Ghostt11@msn.com 

612-990-6900 

Applicant seeks exemption from the requirements of 14 C.F.R Sections 61.113(a)&(b), 91.7(a), 91.121, 91.151(b), 

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

A Brief Description Of The Nature Of The Exemption Applicant Seeks: 

This exemption will permit Applicant to commercially operate an Unmanned Aircraft System (UAS) for the purpose of 

conducting aerial video and photography over certain areas of the United States. 

Any Additional Information, Views, Or Arguments Available To Support Applicant's Request. 

This Petition is made pursuant to the FAA Modernization and Reform Act of 2012 (FMRA) Section 333, which directs 

the Secretary of Transportation to determine if certain UAS may operate safely in the NAS. As such, Applicant'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 certification. As discussed in detail above, Applicant will operate the DJI 

Inspire 1 UASs safely in the NAS, without creating a hazard to users of the NAS, or the public, or otherwise pose a 

threat to national security. 

CONCLUSION 

As set forth herein, Applicant 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 UASs 

commercially, without an airworthiness certificate, for the limited purpose of conducting aerial video and 

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

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

the public, by allowing Applicant to safely, efficiently, and economically operate the 3DR DJI Inspire 1 UASs 

commercially within the NAS. 

WHEREFORE, in accordance with the Federal Aviation Regulations and the FAA Modernization and Reform Act of 

2012, Section 333, Applicant 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 the Applicant to operate the DJI Inspire 1 UASs commercially 

for the purpose nducting aerial video and photography over certain areas of the United States. 

Respec/tf ly s emitted 

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EXHIBIT A 

INSPIRE 1—TECHNICAL SPECS 

Aircraft Model 

T600 Weight (Battery Included) 

2935 g Hovering Accuracy (GPS Mode) 

Vertical: 0.5 m Horizontal: 2.5 m Max Angular Velocity 

Pitch: 300°/s Yaw: 1500 /s Max Tilt Angle 

35° Max Ascent Speed 

5 m/s Max Descent Speed 

4 m/s Max Speed 

22 m/s (ATTI mode, no wind) Max Flight Altitude 

4500 m Max Wind Speed Resistance 

10 m/s Max Flight Time 

Approximately 18 minutes Motor Model 

DJI 3510 Propeller Model 

DJI 1345 Indoor Hovering 

Enabled by default OperatinglTemperature Range 

-10° to 40° C Diagonal Distance 

559 to 581 mm Dimensions 

438x451x301 mm Gimbal Model 

ZENMUSE X3 Output Power (With Camera) 

Static: 9 W In Motion: 11 W Operating Current 

Station: 750 mA Motion: 900 mA Angular Vibration Range 

±0.03 °Mounting 

23 I P a 
Detachable Controllable Range 

Pitch: -90° to +30° Pan: ±320° Mechanical Range 

Pitch: -125° to +45° Pan: ±330° Max Controllable Speed 

Pitch: 120°/s Pan: 180°/s Camera Name 

X3 Model 

FC350 Total Pixels 

12.76M Effective Pixels 

12.4M Image Max Size 

4000x3000 ISO Range 

100-3200 (video) 100-1600 (photo) Electronic Shutter Speed 

8s — 1/8000s FOV (Field Of View) 

94° CMOS 

Sony EXMOR 1/2.3" Lens 

20mm (35mm format equivalent)f/2.8 focus at 0.3 9 Elements in 9 groups Anti-distortion Still Photography Modes 

Single shoot Burst shooting: 3/5/7 frames Auto Exposure Bracketing (AEB): 3/5 bracketed frames at 0.7EV Bias Timelapse Video Recording Modes 

UHD (4K): 4096x2160p24/25, 3840x2160p24/25/30 FHD: 1920x1080p24/25/30/48/50/60 HD: 

1280x720p24/25/30/48/50/60 Max Bitrate Of Video Storage 

60 Mbps Supported File Formats 

FAT32/exFAT Photo: JPEG, DNG Video: MP4/MOV (MPEG-4 AVC/H.264) Supported SD Card Types 

Micro SD Max capacity: 64 GB. Class 10 or UHS-1 rating required. Operating Temperature Range 

0° to 40° C Remote Controller Name 

C1 Operating Frequency 

922.7927.7 MHz (Japan Only) 5.725 -5.825 GHz 2.400-2.483 GHz Transmitting Distance (Outdoor And 

Unobstructed) 

2 km EIRP 

10dBm@900m, 13dBm@5.8G, 20dBm@2.4G Video Output Port 

24IPage 
USB, mini-HDMI Power Supply 

Built-in battery Charging 

DJI charger Dual User Capability 

Host-and-Slave connection Mobile Device Holder 

Tablet or Phone Max Mobile Device Width 

170mm Output Power 

9 W Operating Temperature Range 

-10°to 40°C Storage Temperature Range 

Less than 3 months: -20° to 45° C More than 3 months: 22° to 28° C Charging Temperature Range 

0-40° C Battery 

6000 mAh LiPo 2S Charger Model 

A14-100P1A Voltage 

26.3 V Rated Power 

100 W Battery (Standard) Name 

Intelligent Flight Battery Model 

TB47 Capacity 

4500 mAh Voltage 

22.2 V Battery Type 

LiPo6S High voltage battery Energy 

99.9 Wh Net Weight 

570 g Operating Temperature Range 

-10° to 40° C Storage Temperature Range 

Less than 3 months: -20° to 45° C More than 3 months: 22° C to 28° C Charging Temperature Range 

0° to 40° C Max Charging Power 

25 IPage 
180 W Battery (Optional) Name 

Intelligent Flight Battery Model 

TB48 Capacity 

5700 mAh Voltage 

22.8 V 

Battery Type 

LiPo 6S Energy 

129.96 Wh Net Weight 

670 g Operating Temperature Range 

-10° to 40° C Storage Temperature Range 

Less than 3 months: -20 to 45° C More than 3 months: 22° to 28° C Charging Temperature Range 

0° to 40° C Max Charging Power 

180 W Vision Positioning Velocity Range 

Below 8 m/s (2 m above ground) Altitude Range 

5-500 cm Operating Environment 

Brightly lit (lux > 15) patterned surfaces Operating Range 

0-250 cm DJI GO App Mobile Device System Requirements 

iOS 8.0 or later, Android 4.1.2 or later Supported Mobile Devices 

* Compatible with iPhone 5s, iPhone 6, iPhone 6 Plus, iPad Air, iPad Air Wi-Fi + Cellular, iPad maini 2, iPad mini 2 WiFi + Cellular, iPad Air 2, iPad Air 2 Wi-Fi + Cellular, iPad mini 3, and iPad mini 3 Wi-Fi + Cellular. This app is optimized 

for iPhone Ss, iPhone 6, and iPhone 6 Plus. * Compatible with Samsung tabs 705c, Samsung S6, Samsung S5, Samsung 

NOTE4, Samsung NOTE3, Google Nexus 9, Google Nexus 7 II, Ascend Mate7, Nubia Z7 mini, SONY Z3 EXPERIA, MI 3, 

MI PAD *Support for additional Android devices available as testing and development continues. 

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