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UNITED STATES OF AMERICA

DEPARTMENT OF TRANSPORTATION

FEDERAL AVIATION ADMINISTRATION

WASHINGTON, DC

Regulatory Docket No. _______________

IN THE MATTER OF THE PETITION FOR EXEMPTION OF:

HOVERCAMS LLC

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 April 21, 2015

HOVERCAMS LLC

622 Ottillia Street SE,

Grand Rapids, MI

616-295-6733
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TABLE OF CONTENTS

Pages

GLOSSARY OF ABBREVIATIONS.............................................................................................3

SUMMARY....................................................................................................................................4

INTRODUCTION AND INTERESTS OF PETITIONER.............................................................4

BACKGROUND.............................................................................................................................5

BASIS FOR PETITION..............................................................................................................6-7

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

THE SPECIFIC SECTIONS OF 14 C.F.R. FROM WHICH HOVERCAMS LLC

SEEKS EXEMPTION................................................................................................................8-10

THE EXTENT OF RELIEF HOVERCAMS LLC SEEKS AND THE REASON

HOVERCAMS LLC SEEKS THE RELIEF.......................................................................11-13

THE REASONS WHY GRANTING HOVERCAMS LLC's REQUEST

WOULD BE IN THE PUBLIC INTEREST .........................................................................13-15

THE REASONS WHY GRANTING THE EXEMPTION WOULD NOT

ADVERSELY AFFECT SAFETY..........................................................................................16-28

SUMMARY THAT CAN BE PUBLISHED IN THE FEDERAL REGISTER...........................28

ANY ADDITIONAL INFORMATION, VIEWS, OR ARGUMENTS

AVAILABLE TO SUPPORT HOVERCAMS LLC's REQUEST...............................................28

CONCLUSION........................................................................................................................28-29

APPENDICES...............................................................................................................................30
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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 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

HOVERCAMS LLC 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 HOVERCAMS LLC to operate an 

Unmanned Aircraft System (UAS) for the commercial purpose of conducting aerial video and 

photography of construction sites, real estate, and landscape over certain areas of the United 

States.

INTRODUCTION AND INTERESTS OF THE PETITIONER

HOVERCAMS LLC provides its clients with expertise and knowledge in advanced technologies 

and solutions to increase efficiency, productivity and effectiveness.

HOVERCAMS LLC has over 3 years of recreational/hobby experience in all aspects of aerial 

photography using small Unmanned Aerial Systems (UAS). The objective of HOVERCAMS 

LLC aerial photography and video operations is to provide high quality imaging for a variety of 

commercial, public, and residential uses, specifically targeting:

· Construction sites before and after

· Appraisals

· Real-estate marketing

· Motion Picture Filming

· Aerial acquisitions used for inspections of public and private structures.
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BACKGROUND

HOVERCAMS LLC seeks an exemption to operate DJI Inspire 1 UAS 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 is equipped with four main rotors; driven by Lithium Polymer battery powered 

electric motors.

The DJI Inspire 1 that will be operated by HOVERCAMS LLC 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. Reservation of aircraft number has already been made by the Owner and Pilot In 

Command (PIC) of the DJI Inspire 1 per Exhibit F in the Appendices.
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BASIS FOR PETITION

Petitioner, HOVERCAMS LLC, pursuant to the provisions of the Federal Aviation Regulations 

(14 C.F.R. § 11.61) and the FAA Modernization and Reform Act of 2012 (FMRA), Section 333, 

Special Rules for Certain Unmanned Aircraft Systems, hereby petitions the Administrator to 

commercially operate the DJI Inspire 1 UAS in the National Airspace System (NAS), and for an 

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

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

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

unmanned aircraft and its operation, HOVERCAMS LLC's operation of DJI Inspire 1 UAS 

meets the conditions of FMRA Section 333 and therefore, will not require an airworthiness 

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

Accordingly, HOVERCAMS LLC 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.

HOVERCAMS LLC submits that the requested relief is proper since an equivalent level of 

safety will be ensured. HOVERCAMS LLC 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, HOVERCAMS LLC 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 HOVERCAMS LLC to the extent necessary 

to allow a Pilot in Command (PIC) holding a private pilot or higher level certificate, as well as 

an airman medical certificate, and who has demonstrated, by meeting minimum flight-hour and 

currency requirements, that the PIC is able to safely operate the DJI Inspire 1 UAS in a manner 

consistent with this exemption, including evasive and emergency maneuvers and maintaining 

appropriate distances from people, vessels, vehicles and structures.
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HOVERCAMS LLC 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, HOVERCAMS LLC submits that it will ensure that the 

DJI Inspire 1 UAS is in an airworthy condition, prior to every flight, by determining that the 

UAS is in compliance with the operating documents (i.e., Monthly Maintenance Log, and DJI 

Inspire 1 Instruction Manual), and that the aircraft is in a condition for safe flight.

HOVERCAMS LLC 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 1UAS will be provided to the PIC via Global 

Positioning System (GPS) equipment and radio communications telemetry data link, which 

downlinks from the UAS to the GCS for active monitoring of the flight path. This altitude 

information, combined with HOVERCAMS LLC's operation of the DJI Inspire 1 UAS within 

visual line of sight, at or below 500 feet AGL, will ensure a level of safety equivalent to Section 

91.121.

Additionally, HOVERCAMS LLC seeks an exemption from the requirements of Section 

91.151(b), entitled Fuel requirements for flight in VFR conditions. HOVERCAMS LLC submits 

that safety will not be affected by operation of the DJI Inspire 1 UAS during daylight hours in 

visual meteorological conditions (VMC) under visual flight rules (VFR), with enough battery 

power to fly for a total duration of approximately 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, HOVERCAMS LLC 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:

Craig D. Newhouse

HOVERCAMS LLC

622 Ottillia Street SE,

Grand Rapids, MI 49507

616-295-6733

Email: newhouse.craig@gmail.com
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B. The Specific Sections Of 14 C.F.R. From Which HOVERCAMS LLC Seeks Exemption.

1. HOVERCAMS LLC 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. HOVERCAMS LLC Seeks Exemption From The Requirements Of Section 91.7(a).

Section 91.7, entitled Civil aircraft airworthiness, subsection (a), states the following:

(a) No person may operate a civil aircraft unless it is in an airworthy condition.

3. HOVERCAMS LLC 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.

4. HOVERCAMS LLC 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:
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(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. HOVERCAMS LLC 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.

6. HOVERCAMS LLC 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.

7. HOVERCAMS LLC 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. HOVERCAMS LLC 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:
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(1) Records of the maintenance, preventive maintenance, and alteration and records of the 100-

hour, annual, progressive, and other required or approved inspections, as appropriate, for each 

aircraft (including the airframe) and each engine, propeller, rotor, and appliance of an aircraft. 

The records must include--

(i) A description (or reference to data acceptable to the Administrator) of the work performed; 

and

(ii) The date of completion of the work performed; and

(iii) The signature, and certificate number of the person approving the aircraft for return to 

service.

(2) Records containing the following information:

(i) The total time in service of the airframe, each engine, each propeller, and each rotor.

(ii) The current status of life-limited parts of each airframe, engine, propeller, rotor, and 

appliance.

(iii) The time since last overhaul of all items installed on the aircraft which are required to be 

overhauled on a specified time basis.

(iv) The current inspection status of the aircraft, including the time since the last inspection

required by the inspection program under which 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.
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C. The Extent Of Relief HOVERCAMS LLC Seeks And The Reason HOVERCAMS LLC 

Seeks The Relief.

1. Extent Of Relief HOVERCAMS LLC Seeks And The Reason HOVERCAMS LLC 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 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, HOVERCAMS LLC 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, HOVERCAMS LLC submits that all flights of the DJI Inspire 1 UAS, conducted by the 

PIC pursuant to the grant of this Petition: (1) will be incidental to HOVERCAMS LLC's 

business; and (2) will not carry passengers or property for compensation or hire.

2. Extent Of Relief HOVERCAMS LLC Seeks And The Reason HOVERCAMS LLC 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 HOVERCAMS LLC 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 HOVERCAMS LLC Aerial Operations Manual, Monthly Maintenance Log, 

and DJI Inspire 1 Instruction Manual).

HOVERCAMS LLC seeks the requested relief because the DJI Inspire 1 UAS does not require 

an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. Therefore, 
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HOVERCAMS LLC will ensure that the DJI Inspire 1 UAS is in airworthy condition based upon 

its compliance with the operating documents (i.e., Monthly Maintenance Log, and DJI Inspire 1 

Instruction Manual) prior to every flight, and further, determine that the aircraft is in condition 

for safe flight, as stated in the conditions and limitations below.

3. Extent Of Relief HOVERCAMS LLC Seeks And The Reason HOVERCAMS LLC Seeks 

Relief From Section 91.121.

Relief from Section 91.121, entitled Altimeter settings, may be required to allow flight 

operations of the DJI Inspire 1 UAS, which utilizes a barometric pressure sensor, GPS 

equipment, and a radio communications telemetry data link to downlink altitude information 

from the UAS 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), HOVERCAMS LLC seeks the requested relief because the DJI 

Inspire 1 UAS’s altimeter may be set on the ground to zero feet AGL, rather than the local 

barometric pressure or field altitude, before each flight.

Considering the limited altitude of the proposed operations, relief from 14 CFR 91.121 is sought 

to the extent necessary to comply with the applicable conditions and limitations stated below. As 

more fully set forth herein, an equivalent level of safety will be maintained since the DJI Inspire 

1 UAS is equipped with a barometric pressure sensor and GPS equipment, which automatically 

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

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

4. Extent Of Relief HOVERCAMS LLC Seeks And The Reason HOVERCAMS LLC Seeks 

Relief From Section 91.151(b).

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

requested to the extent required to allow flights of the battery powered DJI Inspire 1 UAS during 

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

total duration of 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. HOVERCAMS LLC 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 HOVERCAMS LLC proposes to conduct pursuant to this 

Petition.
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Significantly, as set forth below, the technical specifications of the DJI Inspire 1 UAS, the DJI 

Inspire 1 operating documents, and HOVERCAMS LLC's proposed operating limitations, ensure 

that HOVERCAMS LLC will safely operate the battery powered DJI Inspire 1 UAS during 

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

enough battery power to fly for a total duration of 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 HOVERCAMS LLC Seeks And The Reason HOVERCAMS LLC 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, HOVERCAMS LLC 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, HOVERCAMS LLC 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 HOVERCAMS 

LLC Aerial Operations Manual, Monthly Maintenance Log, and DJI Inspire 1 Instruction 

Manual). Furthermore, HOVERCAMS LLC will document and maintain all maintenance 

records for the DJI Inspire 1 UAS.

D. The Reasons Why Granting HOVERCAMS LLC 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 HOVERCAMS LLC 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 will decrease congestion of the NAS, reduce 

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

HOVERCAMS LLC's proposed operation of the DJI Inspire 1 UAS will be realized without 

implicating any privacy issues.

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

The DJI Inspire 1 UAS is battery powered and serves as a safe, efficient, and economical 

alternative to the manned aircraft traditionally utilized to obtain aerial imagery. By reducing the 

amount of manned aircraft needed to perform aerial acquisitions, an exemption allowing the use 
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of a DJI Inspire 1 UAS would reduce the amount of manned aircraft in the NAS, reduce noise 

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

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

around airports caused by arriving and departing aircraft will be reduced. The DJI Inspire 1 

UAS does not require an airport to takeoff or land.

Likewise, a reduction of manned aircraft conducting aerial video and photography missions 

would result in fewer manned aircraft that must be handled by air traffic control during the 

ground, takeoff, departure, arrival, and landing phases of flight operations.

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

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

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

during traditional aerial video and still photography, manned flight operations. By using battery 

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

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

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

approximately 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 UA is 

propelled by battery powered electric motors, rather than an internal combustion engine.

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

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

flight operations, will be substantially reduced or completely eliminated. Aside from the lack of 

flight crew members located onboard the aircraft, the DJI Inspire 1 UAS (weighing

approximately 6 pounds 7.5 ounces, at its maximum gross weight with its 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).
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3. Performing Aerial Video and Photography Operations With The DJI Inspire 1 UAS Will 

Benefit The Economy.

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

using manned aircraft to conduct similar aerial operations. As such, operation of the DJI Inspire 

1 UAS will allow United States based companies, like HOVERCAMS LLC, 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 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 HOVERCAMS LLC, 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, HOVERCAMS LLC'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 HOVERCAMS LLC Aerial Operations Manual, Monthly 

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

involvement as well as local law enforcement notification, and in accordance with the Federal 

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

1. Reasons Why The DJI Inspire 1 UAS Meets The Conditions Of The FAA Modernization 

and Reform Act of 2012 (FMRA) Section 333.

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

unmanned aircraft and its operation, HOVERCAMS LLC operation of the DJI Inspire 1 UAS 

meets the conditions of FMRA Section 333, and will not require an airworthiness certificate in 

accordance with 14 C.F.R. Part 21, Subpart H.

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

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

public, or otherwise pose a threat to national security.

Specifically, FMRA Section 333 states the following, in part:

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

days after the date of enactment of this Act, the Secretary of Transportation shall determine if 

certain unmanned aircraft systems may operate safely in the national airspace system before 

completion of the plan and rulemaking required by section 332 of this Act or the guidance 

required by section 334 of this Act.

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

(a), the Secretary shall determine, at a minimum--

(1) which types of unmanned aircraft systems, if any, as a result of their size, weight, speed, 

operational capability, proximity to airports and populated areas, and operation 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.
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In seeking this exemption, HOVERCAMS LLC submits that the DJI Inspire 1 UAS can operate 

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

the DJI Inspire 1 UAS; (b) the pilot certification requirement; and (c) the specific operating

limitations.

a. The Specifications Of The DJI Inspire 1 UAS Demonstrate 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 are set forth by the DJI Inspire 1 Technical 

Specifications Data Sheet attached hereto as Exhibit A.

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

Remain Within A Defined Operational Area.

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

complete description of the flight and navigational modes of the DJI Inspire 1 UAS is provided 

at page 12 of the DJI Inspire 1 Manufacturer’s User Manual, attached hereto as Exhibit B.

iii. The DJI Inspire 1 UAS Is Designed For Automatic Return To Home Point Or Hover In 

The Event Of Loss Of The Control Link Or Navigation.

When the Control Link is lost, the DJI Inspire 1 UA will remain stationary, in flight, for 3

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

from the GCS, the UAS 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 shut

down.

A complete description of the Failsafe Functions of the UAS are set forth for the DJI Inspire 1 at 

pages 13 through 16 of the DJI Inspire 1 Manufacturer’s User Manual, attached hereto as Exhibit 

B.

iv. The DJI Inspire 1 GCS And Its Operation.

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

control software is provided at pages 40 through 48 of the DJI Inspire 1 Manufacturer’s User 

Manual which is attached hereto as Exhibit B.

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

Certificated Pilot in Command With A Safety Observer.
18

HOVERCAMS LLC will only utilize certificated pilots who possess a current and valid airman 

medical certificate to act as a pilot in command (PIC) of the DJI Inspire 1 UAS. Additionally, a 

Safety Observer (SO) will assist all pilots during flight time.

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

Limitations.

In seeking this exemption, HOVERCAMS LLC 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 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.

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

of aerial video and photography.

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

4. The UAS must be operated at an altitude of no more than 500 feet above ground level (AGL), 

as indicated by the procedures specified in the operating documents 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.
19

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 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 
20

in service, description of work accomplished, and the signature of the authorized person 

returning the UAS to service.

15. Each UAS operated under this exemption must comply with all manufacturer 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 UAS may not operate within 5 nautical miles of an airport reference point as denoted on 

a current FAA-published aeronautical chart unless a letter of agreement with that airport’s 

management is obtained, and the operation is conducted in accordance with a NOTAM as 

required by the operator’s COA.

The letter of agreement with the airport management must be made available to the 

Administrator upon request.

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

from a cloud or when visibility is less than 3 statute miles from the PIC.

22. If the UAS loses communications or loses its GPS signal, it must return to a predetermined
21

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 forecast weather 

conditions) there is enough power to fly at normal cruising speed to the intended landing point 

and land the UAS with 25% battery power remaining.

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

Authorization (COA) prior to conducting any operations under the grant of exemption. This 

COA will also require the operator to request a Notice to Airman (NOTAM) not more than 72 

hours in advance, but not less than 48 hours prior to the operation. All operations shall be 

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

airspace, altitude level and potential transponder requirements.

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

registered in accordance with 14 C.F.R. part 47, and have identification (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 UAS 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 50 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 

UAS 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 
22

such protection and are within 50 feet of the UAS, 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.

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.

HOVERCAMS LLC 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 in a manner consistent with the 

exemption, including evasive and emergency maneuvers and maintaining appropriate distances 

from people, vessels, vehicles and structures.

Considering HOVERCAMS LLC'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, HOVERCAMS LLC submits that the additional manned 

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

skills necessary for HOVERCAMS LLC's specific proposed flight operations.

The FAA has previously granted relief from Section 61.113(a) and (b) specific to
23

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).

HOVERCAMS LLC 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 HOVERCAMS LLC'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 flighthour 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 
24

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 UAS with appropriate distances in accordance with 14 C.F.R 91.119. Exemption No. 11138 

at page 15.

Accordingly, HOVERCAMS LLC 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 be maintained because prior to 

every flight, HOVERCAMS LLC 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 PIC via GPS equipment and 

a radio communications telemetry data link, which downlinks from the UAS to the GCS for 

active monitoring of the flight path and altitude. This altitude information, combined with 

HOVERCAMS LLC'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 UAS at ground level.
25

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 DJI Inspire 1 UAS; (2) the 

limitations on the proposed flight operations; and (3) the location of the proposed flight 

operations. Accordingly, HOVERCAMS LLC will ensure that it will safely 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 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 provides 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 Inspire 1 UAS will descend and land 

automatically.

Significantly, previous exemptions granted by the FAA concerning Section 91.151 establish that 

safety is not adversely affected when the technical characteristics and operating 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).
26

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, HOVERCAMS LLC 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 

HOVERCAMS LLC will use trained technicians to perform maintenance, alterations, or 

preventive maintenance on the UAS using the methods, techniques, and practices prescribed in 

the operating documents (i.e., the DJI Inspire 1 Manufacturer’s User Manual, DJI Inspire 1 

Monthly Maintenance Log, and the DJI Inspire 1 Manufacturer’s Maintenance Manual). 

Furthermore, HOVERCAMS LLC will document and maintain all maintenance records for the 

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

documents, HOVERCAMS LLC 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 Manufacturer’s 

User Manual are attached hereto as Exhibit B; a copy of the DJI Inspire 1 Monthly Maintenance 

Log is attached hereto as Exhibit E.

Likewise, the exemption sought will not adversely affect safety because HOVERCAMS LLC 

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 UAS 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.

In consideration of HOVERCAMS LLC's proposed operating limitations, the operating 

documents, and the technical aspects of the DJI Inspire 1 UAS, HOVERCAMS LLC 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, 
27

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, HOVERCAMS LLC 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 UAS, 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 HOVERCAMS LLC's intended operation of the DJI Inspire 1 

UAS, which contain such safety standards that the Administrator finds necessary to establish a 
28

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).

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

From Which HOVERCAMS LLC Seeks Exemption:

HOVERCAMS LLC 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 HOVERCAMS LLC Seeks:

This exemption will permit HOVERCAMS LLC 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 

HOVERCAMS LLC’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, HOVERCAMS LLC'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, HOVERCAMS LLC will operate the DJI Inspire 1 UAS safely in 

the NAS, without creating a hazard to users of the NAS, or the public, or otherwise pose a threat 

to national security.

CONCLUSION

As set forth herein, HOVERCAMS LLC seeks an exemption pursuant to 14 C.F.R. § 11.61 and 

Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA), which will permit safe 

operation of the DJI Inspire 1 UAS commercially, without an airworthiness certificate, for the 

limited purpose of conducting aerial video and photography over certain areas of the United

States. By granting this Petition, the FAA Administrator will be fulfilling the Congressional 

mandate of the FAA Modernization and Reform Act of 2012, while also advancing the interests 
29

of the public, by allowing HOVERCAMS LLC to safely, efficiently, and economically operate 

the DJI Inspire 1 UAS commercially within the NAS.

WHEREFORE, in accordance with the Federal Aviation Regulations and the FAA

Modernization and Reform Act of 2012, Section 333, HOVERCAMS LLC 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 HOVERCAMS LLC 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: April 21, 2015

Respectfully submitted,

HOVERCAMS LLC

_________________________

HOVERCAMS LLC

622 Ottillia Street SE,

Grand Rapids, MI

616-295-67338

Email:Newhouse.craig@gmail.com

Appendices:

A – DJI Inspire 1 Manufacturer’s Specifications Data Sheet

B – DJI Inspire 1 Manufacturer’s User Manual

C – DJI Inspire 1 Manufacturer’s Maintenance Manual

D – DJI Inspire 1 Manufacturer’s Safety Guidelines 

E – DJI Inspire 1 Manufacturer’s Intelligent Flight Battery Safety Guidelines

F – DJI Inspire 1 Monthly Maintenance Log

G – “Confirmation of Reservation of United States Registration Numbers” 01/15/2015 Letter
30

APPENDIX – A

DJI INSPIRE 1 TECHNICAL SPECIFICATIONS DATA SHEET
31

DJI INSPIRE 1 TECHNICAL SPECIFICATIONS

HOVERCAMS LLC only utilizes safe and reliable UAS. DJI is an industry leader in small UAS 

production. DJI UAS 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/tablet devices)

1.1 DJI Inspire 1

1.1.1 Aircraft

1.1.1.1 Model – T600

1.1.1.2 Weight (Battery Included) – 6lbs 7.5291oz (2935g)

1.1.1.3 Hovering Accuracy (GPS Mode) – Vertical: 0.5m; Horizontal: 2.5m

1.1.1.4 Max Angular Velocity – Pitch: 3000/s; Yaw: 1500/s

1.1.1.5 Max Tilt Angle - 350

1.1.1.6 Max Ascent Speed – 5m/s

1.1.1.7 Max Descent Speed – 4m/s

1.1.1.8 Max Speed – 22m/s (ATTI mode, no wind – NOT RECOMMENDED)

1.1.1.9 Max Flight Altitude – 4500m

1.1.1.10 Max Wind Resistance – 10m/s

1.1.1.11 Max Flight Time – Approximately 18 minutes

1.1.1.12 Motor Model – DJI 3510

1.1.1.13 Propeller Model – DJI 1345

1.1.1.14 Operating Temperature Range – 140F to 1040F (-100C to 400C)

1.1.1.15 Dimensions – 17 1⁄4” x 17 3⁄4” x 12”

1.1.2 Gimbal

1.1.2.1 Model – ZENMUSE X3

1.1.2.2 Output Power (with camera) – Static: 9W; In Motion: 11W

1.1.2.3 Operating Current – Static: 750mA; In Motion: 900mA

1.1.2.4 Angular Vibration Range - ±0.030

1.1.2.5 Mounting – Detachable

1.1.2.6 Controllable Range – Pitch: -900 to +300; Pan: ±3200
32

1.1.2.7 Mechanical Range – Pitch: -1250 to 450; Pan: ±3300

1.1.2.8 Max Controllable Speed – Pitch: 1200/s; Pan: 1800/s

1.1.3 Camera

1.1.3.1 Name – X3

1.1.3.2 Model – FC350

1.1.3.3 Total Pixels – 12.76M

1.1.3.4 Effective Pixels – 12.4M

1.1.3.5 Image Max Size – 4000x3000

1.1.3.6 ISO Range – 100-3200

1.1.3.7 Field of View - 940

1.1.3.8 CMOS – Sony EXMOR 1/2.3”

1.1.3.9 HD Video Recording – UHD(4K): 4096x2160p24/25,

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

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

1.1.3.10 Operating Temperature Range - 320F - 1040F (00C - 400C)

1.1.4 Transmitter

1.1.4.1 Name – C1

1.1.4.2 Operating Frequency – 5.728-5.850GHz; 2.400-2.483GHz

1.1.4.3 Communicating Distance (unobstructed) – 2000m

1.1.4.4 Output Power – 9W

1.1.4.5 Operating Temperature Range - 140F to 1040F (-100C to 400C)

1.1.4.6 Battery – 600mAh LiPo 2S
33

APPENDIX – B

DJI INSPIRE 1 MANUFACTURER’S USER MANUAL
34

APPENDIX – C

DJI INSPIRE 1 MANUFACTURER’S MAINTENANCE MANUAL
35

APPENDIX – E

DJI INSPIRE 1 MANUFACTURER’S INTELLIGENT FLIGHT BATTERY

SAFETY GUIDELINES
36

APPENDIX – F

DJI INSPIRE 1 MONTHLY MAINTENANCE LOG
37

UAS:_DJI Inspire 1_

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 Damping

Other:

MONTHLY MAINTENANCE LOG

Month :__________ Year: _________
38

APPENDIX - G

“CONFIRMATION OF RESERVATION OF UNITED STATES REGISTRATION 

NUMBERS” 01/15/2015 LETTER