UNITED STATES OF AMERICA 

DEPARTMENT OF TRANSPORTATION

FEDERAL AVIATION ADMINISTRATION 

WASHINGTON, DC

Regulatory Docket No. 

IN THE MATTER OF THE PETITION FOR EXEMPTIONOF:

Christopher Jared Ruxton

FOR AN EXEMPTION SEEKING RELIEF FROM THE REQUIREMENTS OF TITLE 

14 OF THE CODE OF FEDERAL REGULATIONS

SECTIONS 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1),

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

OPERATION OF DJI INSPIRE 1 UNMANNED AIRCRAFT SYSTEMS

PURSUANT TO SECTION 333 OF

THE FAA MODERNIZATION AND REFORM ACT OF 2012

(PUBLIC LAW 112-95)

Submitted on June 18, 2015

Christopher Jared Ruxton 

C.J. Ruxton LLC

166 N Township St

Sedro-Woolley, WA 98284

360-708-2113
2

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

THE REASONS WHY GRANTING THE EXEMPTION WOULD NOT 

ADVERSELY AFFECT SAFETY......................................................................... 18

SUMMARY THAT CAN BE PUBLISHED IN THE FEDERAL REGISTER..... 33

ANY ADDITIONAL INFORMATION, VIEWS, OR ARGUMENTS 

AVAILABLE TO SUPPORT CHRISTOPHER JARED RUXTON’S

REQUEST.......................................................................................................33

CONCLUSION. ....................................................................................................................34

APPENDICES........................................................................................35
3

GLOSSARY OF ABBREVIATIONS

AGL Above Ground Level

AOI Area of Interest

ATC Air Traffic Control

ATO Air Traffic Organization

AV Aerial Vehicle

CFR Code of Federal Regulations

COA Certificate of Authorization

FAA Federal Aviation Administration

FAR Federal Aviation Regulation

GCS Ground Control Station

GPS Global Positioning System

LOL Loss of Link

NAS National Airspace System

NOTAM Notice to Airman

PIC Pilot In Command

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

333 SO Safety Observer

SOP Standard OperatingProcedures

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
4

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 

purpose 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 knowledge in

photography and videography to increase efficiency, productivity and effectiveness.

Christopher Jared Ruxton has over 10 years of professional experience in photography and is 

recognized as an expert in this area. The objective of Christopher Jared Ruxtonaerial 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 public 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 withfour main rotors; 

driven by Lithium Polymer battery powered electricmotors.

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 petitions

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

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

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

and 91.417(a) & (b).

In consideration of the speed, weight, size, and limited operating areaassociated 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 therefore, will not require an 
6

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

Inspire 1 UAs in a manner consistent with this exemption, including evasiveand 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, Christopher 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 Instruction 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 

altimeter 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 flight 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 Jared 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 contact is: 

Christopher Jared Ruxton

C.J. Ruxton LLC

166 N Township St

Sedro-Woolley, WA 98284

360-708-2113

Email: cjruxton@gmail.com 
8

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 pilot may, for compensation or hire, act as PIC of an aircraft in 

connection with any business or employment if—

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

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

2. Christopher Jared Ruxton Seeks Exemption From The Requirements Of

Section 91.7(a).

Section 91.7, entitled Civil aircraft airworthiness, subsection (a), statesthe 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 flight level 

of that aircraft, as the case may be, by reference to an altimeter that isset, 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 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 availablebefore

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 following:

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

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

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

after that for at least 20 minutes.

5. 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 anaircraft—

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

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

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

6. Christopher Jared Ruxton 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 thefollowing:

(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[.]
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 this 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, 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.
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 

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 whichthe 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 theperiods 

prescribed:

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

the work is repeated or superseded by other work or for 1 year after the work is

performed.

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

and transferred with the aircraft at the time the aircraft is sold.

(3) A list of defects furnished to a registered owner or operator under § 43.11 of 

this chapter shall be retained until the defects are repaired and the aircraft is 

approved for return to service.

C.The Extent Of Relief 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 compensation 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 requirements, 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 1UAS, 

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 compensationor

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 aircraft 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 accordance 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., MonthlyMaintenance 

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 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), Christopher 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 equipped with a barometric pressure sensor and GPS 

equipment, which automatically ensures that a ground level pressure settingwill 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 rules 
14

(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. 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 practicality 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 operating 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 rules (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 The 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 airworthiness 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 

operation 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 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.
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 photographyof

real estate, and landscape over certain areas of the United States.

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

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

Jared Ruxton’s proposed operation of the DJI Inspire 1 UAS will be realizedwithout 

implicating any privacy issues.

1. The Public Will Benefit From Decreased Congestion Of The NAS.

The DJI Inspire 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 allowing 

the use of a DJI Inspire 1 UAS would reduce the amount ofmanned aircraft in the NAS, reduce

noise and air pollution, as well as increase the safety of life and property in the air and on the

ground.

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

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

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

aircraft conducting aerial video and photography missions would result infewer aircraft that 

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

phases of flight operations.

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

UAS.

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

will greatly benefit the public by drastically reducing the levels of air and noise pollution 
16

generated during traditional aerial video and still photography flight operations. By using 

battery power and electric motors, the DJI Inspire 1 UAS produces no air pollution, and is the

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

combustion engine aircraft that are typically utilized for aerialvideo and photography, while 

burning approximately 20-30 gallons per hour of leadedaviation fuel. The DJI Inspire 1 UA, 

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

the UAs are propelled by battery powered electricmotors, rather than an internal combustion

engine.

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

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

manned aircraft flight operations, will be substantially reduced or completely eliminated. 

Aside from the lack of flight crew members located onboard the aircraft, the DJI Inspire 1 

UAs (weighing approximately 6 pounds 7.5 ounces at 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 operations(weighing approximately 6,000 pounds with 

a wingspan of approximately 42 feet, a length of 34 feet, and a fuel capacity of 180 gallons).

3. Performing Aerial Video and Photography Operations With The DJI

Inspire 1 UASs Will Benefit The Economy.

In addition to being safe and efficient, the DJI Inspire 1 UAS is also an economical 

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

the DJI Inspire 1 UAS will allow United States based companies, like 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 operated 
17

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 stability to employees

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

financial performance of U.S. companies, through commercial use of the DJI Inspire 1 UAS, 

provides a stable workforce that increases consumer spending; improves local, state, and 

federal tax revenues; and allows companies to invest in research and development in order to

remain competitive both in the United States and abroad.

4. There Are No Privacy Issues.

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

decades, 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 documents (i.e., the Christopher Jared Ruxton AerialOperations 

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 Aviation 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 associated 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 nationalsecurity. Specifically, 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 determinationunder 

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 underthis 

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.
19

In seeking this exemption, Christopher Jared Ruxton submits that the DJI Inspire 1UAS

can operate safely in the NAS pursuant to FMRA Section 333, as demonstrated by: (a)the 

characteristics of the DJI Inspire 1 UAS; (b) the pilot certification requirement; and (c)the 

specific operating limitations.

a. The Specifications Of The DJI Inspire 1 UAS Demonstrates Its Safe 

Characteristics.

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

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

capability.

i. Technical Specifications Of The DJI Inspire 1 UAS.

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

Specifications and Data Sheet, attached hereto as ExhibitA

ii. The DJI Inspire 1 UAS Autonomous Flight And Navigation Modes 

Enable The UAS To Remain Within A Defined OperationalArea.

The DJI Inspire 1 UAS may be operated in both manual and fully autonomous flight 

modes. A complete description of the flight and navigational modes of the DJI Inspire 1 UAS 

is provided at pages 12-16 and 45-50 of the DJI Inspire 1 UserManual, attached here to as 

Exhibit B.

iii. The DJI Inspire 1 UAS Is Designed For Automatic Return ToHome

Point Or Hover In The Event Of Loss Of The Control Link Or 

Navigation.

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

for 3 seconds or more. If, after 3 seconds, the DJI Inspire 1 UA does notreacquire control 

link data from the GCS, the UA will assume that the Control Link is lost and the UA 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
20

through 15 of the User Manuals, attached hereto as ExhibitB.

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 1User

Manual. DJI Inspire 1 User Manual is attached hereto as ExhibitsB.

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 UAS. 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 following

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

pounds maximum gross weight: DJI Inspire 1 Unmanned AircraftSystems. 

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

amend this grant.

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

the purpose of aerial video and photography.

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

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

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

unless a special request is made and approved by ATC. All altitudes reported to 

ATC must be in feet AGL.

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

This requires the PIC to be able to use human vision unaided by any device other 

than corrective lenses, as specified on the PIC’s FAA-issued airman medical

certificate.

6. The use of first person view (FPV) by the PIC or safety observer (SO) is not permitted.
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 verbally at all times. Electronic messaging or 

texting is not permitted during flight operations. The PIC must be designated before 

the flight and cannot transfer his or her designation for the duration of the flight. The 

PIC must ensure that the SO can perform the functions prescribed in the operating

documents.

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

and avoiding other air traffic and other ground based obstacles/obstructions and is 

not permitted to operate the camera or other instruments.

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

operations and made available to the Administrator upon request. If a discrepancy 

exists between the conditions and limitations contained in the grant of exemption 

and the procedures outlined in the operating documents,the conditions and 

limitations contained in the grant of exemption take precedence and must be 

followed. Otherwise, the operator must follow the procedures as outlined in its 

operating documents. The operator may update or revise its operating documents. It 

is the operator’s responsibility to track such revisions and present updated and 

revised documents to the Administrator upon request. The operator must also 

present updated and revised documents if it petitions for extension or amendment to 

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

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

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

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

to the operating documents.

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

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

of the UAS, the aircraft is prohibited from operating until the necessary 

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

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

inspection. All maintenance and alterations must be properly documented in the 

aircraft records.

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

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

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

flight must make an entry in the aircraft records.

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

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

relevant sections of the operating documents.

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

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

14. The operator must carry out its maintenance, inspections, and record keeping 
22

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 meetsthe 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. §

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 within 5 nautical miles of an airport reference point as 

denoted on a current FAA-published aeronautical chart unless a letter of agreement 

with that airport’s management is obtained, and the operation is conducted in 

accordance with a NOTAM as required by the operator’s COA. The letter of 

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

upon request.

21. The 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 predetermined location within the planned operating area and land or be recovered in 

accordance with the operating documents.

23. The PIC must abort the flight in the event of unpredicted obstacles or 

emergencies in accordance with the operating documents.

24. The PIC is prohibited from beginning a flight unless (considering wind and 
23

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 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 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 hasgranted

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 
24

permission from the land owner/controller or authorized representative. 

Permission from land owner/controller or authorized representative will be

obtained for each flight to be conducted.

33. Any incident, accident, or flight operation that transgresses the lateral or vertical 

boundaries of the operational area as defined by the applicable COA must be 

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

Accidents must be reported to the National Transportation Safety Board (NTSB) 

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

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

And (b) Would Not Adversely Affect Safety.

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 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 ina manner 

consistent with the exemption, including evasive and emergency maneuvers 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 flightoperations.

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).

Christopher Jared Ruxton 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
25

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

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

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

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

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

also have accumulated and logged a minimum of 5 hours as a UAS pilot operating the 

same make and model of UAS to be used for operations under the exemption. For 

clarification, the FAA considers these minimum hour requirements to be inclusive 

rather than additive; i.e. 5 hours make and model time may be included in the 10 hours 

of multi-rotor time and the 10 hours may be included in the total 25 hours of UAS 

rotorcraft time. In addition to the hour requirements, the PIC must accomplish 3 

takeoffs and landings in the preceding 90 days (for

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

Exemption No. 11062 are appropriate to practice and build proficiency in the skills 

necessary to safely conduct the petitioner’s proposed operations. The FAA also finds 

that prior documented flight experience that was obtained in compliance
26

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, Christopher Jared Ruxton 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.

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 bemaintained 

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

4. Reasons Why An Exemption From The Requirements Of Section 91.121 

Would Not Adversely Affect Safety.

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

the altitude information of the DJI Inspire 1 UAs will be provided to the PICvia GPS 

equipment and a radio communications telemetry data link, which downlinks from
27

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

information, 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 material respects, to those presented herein (e.g. Exemption Nos. 

11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11112, 11136, 11138,

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

5. Reasons Why An Exemption From The Requirements Of Section 91.151(b) 

Would Not Adversely Affect Safety.

A grant of this exemption would ensure an equivalent level of safety established by 14 

C.F.R. Section 91.151(b) as a result of (1) the technical specifications of the DJIInspire 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 willsafely operate 

the battery powered DJI Inspire 1 UA during daylight hours in VFRconditions, 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 

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 provideaudible
28

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

first warning occurring at approximately 33% remaining battery power, and again at 

approximately 10% remaining battery power. At the critically low battery level, the DJI Inspire 

1 UAs will descend and land automatically.

Significantly, previous exemptions granted by the FAA concerning Section 91.151

establish that safety is not adversely affected when the technical characteristicsand operating 

limitations of the UAS are considered. Relief has been granted for manned aircraft to operate at 

less than the minimums prescribed in Section 91.151, including Exemption Nos. 2689, 5745, 

and 10650. Moreover, the FAA has previously granted relief from Section 91.151 specific to 

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

Exemption Nos. 8811, 10808, 10673, 11042, 11062, 11063,

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

11157, 11158, 11159, 11160, 11161).

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

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

Adversely Affect Safety.

In seeking this exemption, Christopher Jared Ruxton 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 Christopher Jared Ruxton will use trained technicians to performmaintenance,

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

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

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 theoperating

documents, Christopher Jared 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 1User 

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

attached hereto 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 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 willbe documented and 

maintained utilizing the monthly maintenance log.

Significantly, previous exemptions granted by the FAA concerningSections 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 relief 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, 11161).

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

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

(FMRA) and 14 C.F.R. § 21.16 entitled Special Conditions, Christopher Jared Ruxton requests 

that the FAA prescribe special conditions for the intended operation of the DJI Inspire 1 UAS, 

which contain such safety standards that the Administrator finds necessary to establish a level

of safety equivalent to that established by 14 C.F.R. Part 21, Subpart H, and 14 C.F.R §§ 

61.113(a) & (b), 91.7 (a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1),

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

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

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

requirements for considering whether a UAS will create a hazard to users of the NAS or the 

public, or otherwise pose a threat to national security; and further, provides the authority for 

such UAS to operate without airworthiness certification in accordance with any requirements 

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

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

§ 21.16, for operation of the DJI Inspire 1 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.
32

The special conditions are issued in accordance with Part 11 of this chapter and 

contain such safety standards for the aircraft, aircraft engine or propeller as the FAA 

finds necessary to establish a level of safety equivalent to that established in the

regulations.

See 14 C.F.R. § 21.16.

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

prescribe special conditions for Leading Edge’s intended operation of the DJI Inspire 1 UAS, 

which contain such safety standards that the Administrator finds necessary to establish a level

of safety equivalent to that established by 14 C.F.R. Part 21, Subpart H, and 14 C.F.R Sections 

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

91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b).
33

F. A Summary That Can Be Published In The Federal Register, stating: The Rules 

From Which 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 Description 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 areas 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 Secretary 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 withoutairworthiness

certification.

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 nationalsecurity.
34

CONCLUSION

As set forth 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, 

withoutan 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 Christopher Jared Ruxton to safely, efficiently, and economically 

operate the DJI Inspire 1UAS commercially within the NAS.

WHEREFORE, in accordance with the Federal Aviation Regulations and theFAA

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 the 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

360-708-2113
35

Appendices:

A – DJI Inspire 1 Specifications DataSheet

B – DJI Inspire 1 Manufacturer’s UserManual

C – Monthly Maintenance Log
36

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 software enabling the user

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

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

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

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

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	Resistance	– 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)	– Static:	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	Speed	– Pitch:	1200/s;	Pan: 1800/s

2.2.3 Camera

2.2.3.1 Name	– X3

2.2.3.2 Model	– FC350
37

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): 4096x2160p24/25,

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	2S
38

APPENDIX – B

DJI Inspire 1 Manufacturer’s User Manual

http://download.djiinnovations.com/downloads/inspire_1/en/Inspire_1_User_Manual_v1.2_en.pdf
39

APPENDIX – C

MONTHLY$MAINTENANCE$LOG

month: (year:

UAS$#:$ Date(Issue(

Discovered

Date(Issue(

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

Print(&(Sign

Software(Updates

Airframe(

Engines

Propellers

Camera(Gimbal

Landing(Gear

Vibration(Dampening

Other: