UNITED STATES OF AMERICA

DEPARTMENT OF TRANSPORTATION

FEDERAL AVIATION ADMINISTRATION

Exemption Request Section 333 of the FAA Reform Act

Docket Management System 

1200 New Jersey Ave., SE 

Washington, DC 20590 

Regulatory Docket Number ______________

Petitioner: October 7, 2015 

Michael J. Pettit 

200 E. Racquet Club Rd. Unit 6 

Palm Springs, Ca. 92262 

760-327-8625 

petitemichael@hotmail.com 

DEAR SIR, MADAM; 

This petition is being submitted on my own behalf in accordance with the FAA’s 

Guidelines for Submitting a Petition for Exemption under section 333 of the FAA 
Modernization and Reform Act of 2012. I Michael J. Pettit, referred to hereafter as 

the petitioner / operator, request exemption from the following sections of the 

Federal Aviation Regulations for the purpose of aerial photography, videography, 

advertising, real estate inspections and promotions, golf course construction, 

maintenance, and promotional ads, surveying and mapping operations, crop 

surveying, construction site development, and inspections of towers and other 

structures. 

14 C.F.R. 45.23 (b) 

14 C.F.R. Part 21 (h) 

14 C.F.R. 61.113 (a) (b), 91.7 (a), 91.9 (b) (2), 91.103 (b), 91.119, 91.121, 91.151 (a), 

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

The petitioner / Operator holds a private pilot license, single engine land with an 

instrument rating, and a valid California Drivers License. The Petitioner / Operator 

also has 50+ hrs. flying and operating small RC aircraft. The aircraft to be used 

during these commercial operations will be the DJI Inspire 1. 

UAS

Please see the following attachments and or links for the DJI Inspire 1. 

Specifications: http://www.dji.com/product/inspire-1/spec

Maintenance Manual: http://download.djiinnovations.com/downloads/inspire_1/en/Inspire_1_Maintenance_ManualV1.0_en.pdf 

User Manual: http://download.djiinnovations.com/downloads/inspire_1/en/Inspire_1_User_Manual_v1.0_en.pdf

Operations will be performed only at the request of and with the authorization and 

permission of clients or their authorized agents in order to facilitate commerce and 

raise awareness of the beneficial uses of small unmanned air systems. So long as 

such operations are conducted within and under the conditions outlined herein or as 

may be established by the FAA as required by Section 333. 

The DJI Inspire 1 utilizes an internal inertial measuring unit (IMU) with integrated 

barometric sensor augmented with global positioning system (GPS) to maintain its 

geospatial orientation and position. It is controlled primarily through an FCC 
certified radio control (RC) unit. Real time video and telemetry information is 

transmitted back to ground control station allowing the operator and/or PIC to 

monitor battery level GPS signal strength, altitude (AGL), distance from PIC, camera 

imagery, and control camera angle. It has failsafe modes of operation for either loss 

of RC or GPS signal. Altitude can be limited by the onboard flight controller and 

maximum altitude can be preprogrammed by the PIC. Battery life limits flight times 

to approximately 25 minutes. The onboard flight controller will warn the pilot via 

telemetry and external lighting cues before reaching a low battery state. An 

automatic termination of flight and landing will be initiated when the battery reaches 

a predetermined low state. It is anticipated the flights will usually last less than 10 

minutes. 

SAFTEY FEATURES

The UAS has several safety features which will minimize the potential for fly-aways 

and maximize the safe and efficient use of the aircraft in the NAS. The DJI Inspire 

controller provides Intelligent Orientation control (Home Lock and Course Lock 

Features.) The Hone Lock Feature allows for a safe return should the operator get 

disoriented as to the direction the aircraft is moving. Once activated on the remote 

control, the operator can simply pull back on the right control stick and Inspire will 

return to the remote control regardless of the aircraft’s location from the remote 

control. 

The “lost – link” feature will allow the Inspire to climb or descend to a pre-assigned 

altitude and return to the point of departure and land itself. 

AIRCRAFT OPERATIONS AND EQUIVALENT LEVEL OF SAFTEY 

- Operations authorized by this grant of exemption will be limited to the aircraft 

described in the operating documents, rotorcraft UASs weighing less than 55 

pounds maximum gross weight: DJI Inspire 1 

- The UAs will not be flown at an indicated airspeed exceeding 40 knots. 

- The UAS will 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. 

- Visual line-of-sight (VLOS) only; the unmanned aircraft will remain within 

VLOS of the operator or visual observer, without any other visual aids. (FPV) 

- All operations will be conducted during official daylight hours, local time. 

- A COA will be obtained through the local ATC if operations will be conducted 

outside of class G airspace. Or operation that exceed the blanket COA. 
- The Petitioner will not operate in Class B, C, or D airspace without written 

approval from the FAA. The UAS may not operate within 5 nautical miles of 

the geographic center of non-towered airport as denoted on a current FAApublished aeronautical chart unless a letter of agreement with that airport’s 

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

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

airport management must be made available to the Administrator upon 

request. 

- All operating documents, including the “grant of exemption” will be available 

upon request to the Administration and or Local Authorities. 

- A pre-flight check will be done before each flight / or operation, in strict 

accordance with the DJI Inspire 1 Manual’s pre-flight check list. Any 

maintenance or repairs will be documented in the aircrafts Maintenance Log. 

- The operator will be trained in all flight operation and safety procedures as 

detailed in this document and the DJI Manual, with all the updated information 

related to the DJI Inspire 1. 

Any accident which results in injury or property damage will be reported to the 

FAA within 10 days. 

- The aircraft will be identified by an N-number in accordance with 14 C.F.R. 

Part 47. 

- Radio frequency for all operations will comply with the FCC. 

- The operator is a licensed private pilot with extensive aeronautical 

knowledge. The operator will always yield to manned aircraft, and never 

operate the aircraft from a moving vehicle. 

- Written and / or verbal permission and permits will be obtained from territorial, 

state, county or city jurisdictions, including law enforcement, fire or other 

appropriate governmental agencies. 

-

SPECIFIC EXEMPTIONS AND EXTENT OF RELIEF SOUGHT:

14 C.F.R. 45.23 (b) (Aircraft Identification Number and the word Experimental) 

• The DJI Inspire 1, is an unmanned aircraft with no cabin, cockpit, or pilot 

station. If required the word Restricted or Experimental can be placed on the 

aircraft, in a size appropriate for the space allowed. The same can be 

accomplished with the “N” number if there is not an exemption from the 

aircraft registration process. 
14 C.F.R. PART 21 (h) (Airworthiness Certificate) 

• Given the size and limited operating area associated with the aircraft to be 

utilized by the Petitioner , an exemption from Part 21 Subpart H meets the 

requirements of an equivalent level of safety under Part 11 and Section 333 of 

the Reform Act. The Federal Aviation Act (49 U.S.C. 44701 (f) and Section 333 

of the Reform Act both authorize the FAA to exempt aircraft from the 

requirement for an airworthiness certificate, upon consideration of the size, 

weight, speed, operational capability, and proximity to airports and populated 

areas of the particular UAS. In all cases, an analysis of these criteria 

demonstrates that the UAS operated without an airworthiness certificate, in 

the restricted environment and under the conditions proposed will be at least 

as safe, or safer, than a conventional aircraft operation with an airworthiness 

certificate without the restriction and conditions proposed. 

14 C.F.R. 61.113 (a) (b) (Private Pilot Privileges and Limitations) 

• The petitioner requests relief in order to facilitate the utilization of pilots, who 

hold a Private Pilot certificate and a valid driver’s license, to conduct the 

proposed flight operation for compensation or hire. Any pilots operation under 

this exemption would be required to comply with any conditions as set forth 

and in a similar fashion to the previously granted exemptions. 

91.7 (a) (Civil Aircraft Airworthiness) 

• To the extent that the petitioner’s UAS is not eligible for an airworthiness 

certificate under 14 C.F.R. Part 21, therefore it cannot be airworthy in the 

context of the regulation. 

91.9 (b) (2) ( Civil Aircraft Flight Manual, Marking, and Placard Requirements) 

• The petitioner request an exemption to this requirement since the aircraft is 

not only too small to carry documentation, the documentation would not be 

available to the crew during flight operation. To obtain an equivalent level of 

safety and meet the intent of 91.9, a current, approved UAS Flight Manual will 

be available to the crew at the ground station anytime the aircraft is in, or 

preparing for flight. 

91.103 (b) (Pre-flight Action) 

• Prior to each flight the PIC will conduct a pre-flight check and inspect the UAS 

to ensure that it is in a condition for safe flight and the PIC will also follow all 

operation and flight manual training and procedures as prescribed in the DJI 
Inspire 1’s User’s Manual and Pre-flight checklist. If an inspection reveals a 

condition that affects the safe operation of the UAS, the aircraft is prohibited 

from operation until the necessary repairs have been performed, and the UAS 

is found to be in a condition suitable for safe flight. 

91.119 (c) (Minimum Safe Altitude) 

• As discussed in Exemption 11138 (DOUGLAS TRUDEAU), operations 

conducted closer than 500 feet to the ground may require that the UAS be 

operated closer than 500 feet to essential persons, or objects that would not 

be possible without additional relief. The petitioner requests modification, 

waiver or exemption and clarification concerning the terms “congested areas” 

and “densely populated”. The petitioner (Michael J. Pettit) requests a waiver 

for this condition to allow reasonable and responsible operations with safety 

as my main concern in areas of subdivisions and neighborhoods if required. 

Since the typical mission of the UAS would be photography, surveying of 

persons, vessels, vehicles or structures, it would be necessary to operated 

closer than 500 feet to the items listed. Operations will only be flown over 

property or persons where permission has been obtained and careful preplanning has been performed. 

91.121 (Altimeter Settings) 

• As discussed in Exemption 11138 (DOUGLAS TRUDEAU) this is inapplicable 

since the UAS does not have an altimeter and instead utilizes electronic GPS 

with a barometric sensor for altitude information. An equivalent level of 

safety will be achieved by the operator, pursuant to the safety check list and 

live flight data monitoring, confirming the altitude of the launch site shown on 

the GPS altitude indicator before flight. 

91.151 (a) (Fuel Requirements for Flight in VFR Conditions) 

• The UAS provides battery power remaining in percent to the PIC. The UAS 

batteries provide approximately 25 minutes of powered flight. Information 

provided in operating documents, discuss procedures regarding remaining 

battery power management. Those documents contain a condition in which 

the PIC will initiate a landing procedure when battery power remaining 

reaches a specified level. Given the limitations on proposed operations, and 

the location of those proposed operations, the FAA found that a reduced 

minimum power reserve for flight in daytime VFR conditions was reasonable. 

 91.405 (a), 91.407 (a) (1), 91.409 (a) (2), 91.417 (a) (b) (Maintenance Required) 
• As discussed in Exemption 11138 (DOUGLAS TRUDEAU), The petitioner 

proposes to inspect and ensure that the UAS is in a condition for safe flight in 

accordance with the operation documents. The FAA found that adherence to 

the petitioner’s operation documents and the conditions and limitations 

specified, describing requirements for maintenance, inspection, and 

recordkeeping, were sufficient to ensure that safety would not be adversely 

affected. All required maintenance will be documented and maintained 

utilizing the maintenance log. 

PUBLIC INTEREST

Instead of using manned aircraft, the UAS will greatly benefit the public by 

drastically reducing the levels of air and noise pollution generated during traditional 

aerial flight operations. Without aircrew members and highly flammable fuel 

onboard, there will be less potential for a catastrophic event. Crop surveying 

application could lead to decreased use of pesticides and fertilizers and 

conservation of water as well as increased crop yields and decreased costs. Aerial 

surveying and inspections can increase work site efficiency, improve volumetric 

estimation and reduce risks. The UAS will minimize ecological damage and promote 

economic growth by providing information to businesses and individuals in their 

perspective industries. In the past, it has been cost prohibitive for most small 

businesses to obtain this type of service, due to the low cost operations of the UAS, 

these operations will open up a whole new level of commerce, which will add to 

economic growth for all. 

I, Michael J. Pettit respectfully request exemption under Section 333 to operate 

safe, low-risk commercial UAS operations for the activities stated above. I will 

respect the space of citizens and property and endeavor to keep our skies safe. 

Thank You for Your Consideration. 

Respectfully Yours, 

Michael J. Pettit 

200 E. Racquet Club Rd. Unit 6 

Palm Springs, Ca. 92262 

760-327-8625 

petitemichael@hotmail.com