1

Drone/UAS Practice Group 35 E Wacker Drive

Suite 1875

Chicago, IL 60601

Tel. 312.201.8310

 Jeffrey@Antonelli-Law.com

U.S. Department of Transportation January 29, 2016

Docket Management System

1200 New Jersey Ave S.E. 

Washington, D.C. 20590

Re: Request for Exemption under Section 333 of the FAA Modernization and Reform Act of 

2012 and Part 11 of the Federal Aviation Regulations from Certain Provisions of 14 C.F.R.

JandDImages LLC

Dear Sir or Madam: 

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

Act) and 14 C.F.R. Part 11, Antonelli Law files this petition for exemption on behalf of 

JandDImages LLC (“JandDImages”), an operator of Small Unmanned Aircraft Systems (“UAs”) 

for the commercial purposes of aerial photography and videography for the construction and real 

estate industries. Specifically, petitioner seeks an exemption from the Federal Aviation 

Regulations (“FARs”) listed in Appendix A to allow commercial operation of its UA, so long as 

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

established by the FAA in a grant of this petition. This request is substantially similar to dozens of 

other aerial photography and videography petitions previously approved, and should be considered 

under the expedited summary grant procedure.

Approval of the exemption for petitioner will allow operation of the DJI Inspire 1 Pro for 

the proposed uses in Class G airspace nationwide, or as otherwise prescribed by an Air Traffic 

Organization (ATO) issued COA. The UA covered by this petition has been previously approved 

for the proposed uses in the exemption grants identified in Section VII of the petition. The UA 

covered by this petition is small battery-powered craft, weighing no more than 7.7 lbs. (3.5 kg),

inclusive of battery and payload. Operation of the UA under the strict conditions proposed below 

will provide an equivalent level of safety, as Congress intended, while still allowing commercial 

operations. Operations using this UA is far safer than conventional operations conducted with 

helicopters and fixed-wing aircraft that weigh thousands of pounds, carry large amounts of highly 

flammable fuel, and operate in close proximity to the ground, trees, infrastructure, and people. 

Congress directed the FAA to consider seven factors in deciding whether to approve 

Section 333 exemption petitions - size, weight, speed, operational capability, proximity to airports, 

proximity to populated areas, and operation within visual line of sight. In this case, each factor 
2

supports the exemption request. In particular, the UA is small, and will operate at slow speeds and 

close to the ground. It will be able to more safely and efficiently conduct operations that would 

otherwise involve risk of injury or death. The substantial increase of safety and decrease of risk to 

human life and to property weighs heavily in favor of granting the exemption.

For your ease in reviewing this petition, please refer to the table of contents which begins 

on page 3. If we can provide any additional information to assist your understanding or review of 

these documents, please do not hesitate to contact us at 312-201-8310 or via email at 

jeffrey@antonelli-law.com.

Thank you,

Jeffrey J. Antonelli

Amelia R. Niemi

Benjamin C. Fink

Attorneys for JandDImages LLC
3

Table of Contents

I. Publishable Summary............................................................................................................ 5

II. Petitioner’s Contact Information ........................................................................................... 5

III. Proposed Operations.............................................................................................................. 6

A. The UA........................................................................................................................... 6

B. The Crew ........................................................................................................................ 7

C. Flight Conditions............................................................................................................ 7

D. Flight Operations............................................................................................................ 7

IV. Aircraft and Equivalent Level of Safety................................................................................ 8

VI. Proposed Conditions of the Exemption................................................................................. 8

VI. Privacy................................................................................................................................. 11

VII. Public Interest and Safety...................................................................................................... 12

VIII. Regulations from Which Exemption is Requested .............................................................. 13

Appendix A: FARs as to which JandDImages wishes the same determination to be made as 

has been made previously...................................................................................................... 13
4

Exhibit List

Exhibit 1: DJI Inspire 1 Pro User Manual ..............Submitted separately due to upload constraints

Exhibit 2: DJI Inspire 1 Pro Quick Start Guide ......Submitted separately due to upload constraints

Exhibit 3: DJI Inspire 1 Pro Safety Guidelines and Disclaimer .......................................................

.................................................................................Submitted separately due to upload constraints

Exhibit 4: DJI Inspire 1 Series Intelligent Flight Battery Safety Guidelines....................................

.................................................................................Submitted separately due to upload constraints

Exhibit 5: DJI Phantom Pilot Training Guide.........Submitted separately due to upload constraints

Exhibit 6: DJI Inspire 1 Pro Overview ......................................................................................... 15

Exhibit 7: DJI Inspire 1 Pro Features............................................................................................ 23

Exhibit 8: DJI Inspire 1 Pro Specifications................................................................................... 28

Exhibits 1 through 5 have been uploaded to Regulations.gov separately due to size 

constraints.
5

I. Publishable Summary

Pursuant to 14 C.F.R. §11, the following summary is provided for publication in the 

Federal Register, should it be determined that publication is needed:

Petitioner seeks an exemption from the following rules: 

14 C.F.R 21(h); 14 C.F.R. 43.7; 14 C.F.R. 43.11; 14 C.F.R. 45.11; 14 C.F.R. 45.27; 14 C.F.R. 

45.29; 14 C.F.R. 91.7(a); 14 C.F.R. 91.9(b)(2); 14 C.F.R. 91.9(c); 14 C.F.R. 91.103(b)(2); 14 

C.F.R. 91.105; 14 C.F.R. 91.109; 14 C.F.R. 91.113(b); 14 C.F.R. 91.119 (c); 14 C.F.R. 91.121; 14 

C.F.R. 91.151(a); 14 C.F.R. 91.203(a) and (b); 14 C.F.R. 215; 14 C.F.R. 91.403; 14 C.F.R. 

91.405(a); 14 C.F.R. 91.407(a)(1); 14 C.F.R. 409(a)(1) and (2); and 14 C.F.R. 91.417(a) and (b) 

to operate commercially small unmanned aircraft systems (UAs) (7.7 lbs. or less).

Approval of the exemption requested by petitioner will allow commercial operation of the 

DJI Inspire 1 Pro for the purposes of aerial photography and videography for the construction and 

real estate industries in Class G airspace nationwide, unless otherwise prescribed by an ATOissued COA. The requested exemption should be granted because operation of a small UA

weighing no more than 7.7 lbs. (3.5 kg), inclusive of battery and payload, conducted in the strict 

conditions outlined below, will provide an equivalent level of safety, while still allowing 

commercial operations. The lightweight aircraft covered by the exemption are far safer than 

conventional operations conducted with helicopters and fixed-wing aircraft weighing thousands of 

pounds and carrying large amounts of highly flammable fuel, and operating in close proximity to 

the ground and people. The seven factors Congress directed the FAA to consider when approving 

Section 333 exemption petitions - size, weight, speed, operational capability, proximity to airports, 

proximity to populated areas, and operation within visual line of sight – each support the request. 

In particular, the aircraft are small, and will operate at slow speeds, and close to the ground. The 

substantial increase of safety and decrease of risk to human life, coupled with the low risk use of 

UAs to conduct these operations, weigh heavily in favor of granting the exemption.

II. Petitioner’s Contact Information

David Fisher

Manager

JandDImaging LLC

4734 Terrace Greene Trace

Stone Mountain, GA 30088

Tel: (678) 283-2876

Email: janddimages@aol.com

Counsel for Petitioner:

Jeffrey J. Antonelli

Antonelli Law

35 E Wacker Drive, Suite 1875

Chicago, IL 60601

Tel: 312-201-8310

Email: jeffrey@antonelli-law.com
6

III. Proposed Operations

A. The UA

The requested exemption will permit petitioner to operate the DJI Inspire 1 Pro. This UA

has been previously approved for commercial operation in, among others, the exemption grants 

identified in Section VII below.

The specific conditions of the proposed exemption that relate to the characteristics of the 

UA are numbers 1, 5, and 16-20 in Section V below. Each has been adopted or imposed by the 

FAA in numerous previous grants of Section 333 exemption petitions.

The DJI Inspire 1 Pro have the ability to hover and move in the vertical and horizontal 

planes simultaneously. The UA will have the following specifications or equivalent:

Airframe DJI Inspire 1 Pro

Control System Internal to the Inspire 1. This includes the main controller 

(MC), which receives battery voltage, capacity, and 

current, the internal measurement unit (IMU), which 

receives telemetry data, compass, and GPS.

Maximum Operating Speed 35 knots

Maximum Flight Time 15 minutes

Maximum Weight 7.7 lbs. (3.5 kg)

Transmitter Inspire 1 Pro Remote Controller

Receiver 5.728~5.850 GHz receiver

Motor DJI 3510H

Propellers Four DJI 1345T propellers

Data Link HD Lightbridge Video Downlink

Video Link HD Lightbridge Video Downlink

Batteries LiPo 6S High Voltage battery with 4500-5700 mAh 

capacity

Telemetric Display DJI Pilot App

Automatic Return to Home If Tx signal is lost for more than three seconds and the 

UA is under 65 ft. (20 m.) AGL, the UA will rise to 65 ft. 

AGL, travel horizontally to the predesignated home spot, 

then land. If the UA is above 65 ft. AGL, travel 

horizontally to the predesignated home spot, hover for 15 

seconds, then land.
7

B. The Crew

The crew will consist of a pilot in command (PIC) and a visual observer (VO). The PIC 

and VO will have been trained in operation of UAs generally and received up-to-date information 

on the UA to be operated pursuant to this grant. The PIC will have, at a minimum, a sport pilot 

license and either a third class medical certificate or a U.S. driver’s license.

The specific conditions of the proposed exemption that relate to the training and 

characteristics of the crew are numbers 3 and 6-9 in Section V below. Each has been adopted or 

imposed by the FAA in numerous previous grants of Section 333 exemption petitions.

For more information regarding the flight crew and training, please refer to Exhibit 5: DJI 

Phantom Pilot Training Guide.

C. Flight Conditions

The UA will be used for aerial photography and videography for the construction and real 

estate industries in Class G airspace (unless otherwise prescribed by an ATO-issued COA) under 

400 feet above ground level (“AGL”) and under controlled conditions over restricted property. 

Petitioner will work with the local FSDO when planning operations. Petitioner will only operate 

the UA in visual meteorological conditions (VMC). The UA will at all times be no less than 500 

feet below and no less than 2,000 feet horizontally from a cloud, and petitioner will not conduct 

operations unless visibility is at least 3 statute miles from the PIC. The flight crew will always 

make a safety assessment of the risk of every operation, and will only operate when it is determined 

that no hazards are present.

The specific conditions of the proposed exemption that relate to the flight conditions in 

which the UA will be operated are numbers 2, 4, 16, and 28-29 in Section V below. Each has been 

adopted or imposed by the FAA in numerous previous grants of Section 333 exemption petitions.

D. Flight Operations

The purpose of the UA flights for which exemption is requested will be for aerial 

photography and videography for the construction and real estate industries. Every UA flight will 

use at minimum a two person flight crew: a PIC and a VO. 

The specific conditions of the proposed exemption that relate to flight operations are 

numbers 11-12, 17-25, and 32-34 in Section V below. Each has been accepted or imposed by the 

FAA in numerous previous grants of Section 333 exemption petitions.

For more information regarding flight operations, please refer to the following subsections 

of the Inspire 1 Pro User Manual:

Exhibit 1: DJI Inspire 1 Pro User Manual: Aircraft

Exhibit 1: DJI Inspire 1 Pro User Manual: Flight
8

IV. Aircraft and Equivalent Level of Safety

Petitioner proposes that the exemption apply to UAs that have the characteristics and that 

operate with the limitations proposed herein. These limitations provide for a level of safety at least 

equivalent to or higher than manned aircraft operations under the current regulatory structure. 

Section V below identifies the limitations and conditions to which petitioner agrees to be bound 

when conducting commercial operations under a grant of this petition. Appendix A contains a 

matrix connecting (i) the specific proposed condition with (ii) the FAR provision for which it 

provides an equivalent level of safety and (iii) one or more recent Section 333 exemption grants 

in which the FAA recognized this equivalent level of safety.

Approval of the commercial operations outlined in this petition presents no national security 

issue. The PIC will possess, at minimum, a sport pilot’s certificate, and therefore he or she will 

have been subject to security screening by the Department of Homeland Security.

V. Proposed Conditions of the Exemption

1. The UA, including battery and technical payload, will weigh no more than approximately 7.7 

lbs (3.5 kg).

2. UA operations under this exemption will be limited to conducting operations for the purposes 

of aerial photography and videography for the construction and real estate industries in Class 

G airspace nationwide, unless otherwise prescribed by an ATO-issued COA.

3. Flights will be operated within line of sight of a PIC and VO.

4. Flights will be operated at an altitude of no more than 400 feet AGL, as indicated by the 

procedures specified in the operating documents. All altitudes reported to ATC must be in feet 

AGL.

5. The UA will not be flown at an indicated airspeed exceeding 35 knots. 

6. Minimum flight crew for each operation will consist of the UA PIC and a VO.

7. The PIC will possess at a minimum sport pilot license and either a third class medical certificate 

or a U.S. driver’s license.

8. The petitioner will not permit any PIC to operate the UA unless the PIC meets its qualification 

criteria and demonstrates the ability to safely operate the UA in a manner consistent with how 

the UA will be operated under this exemption, including evasive and emergency maneuvers 

and maintaining appropriate distances from persons, vessels, vehicles and structures. PIC 

qualification flight hours and currency will be logged in a manner consistent with 14 CFR 

§61.51(b). A record of the PIC training will be documented and made available upon request 

by the Administrator. Training operations will only be conducted during dedicated training 

sessions. During training, proficiency, and experience-building flights, all persons not essential 

for flight operations will be considered nonparticipants, and the PIC will operate the UA with 

appropriate distance from nonparticipants in accordance with 14 CFR § 91.119. 
9

9. The VO will not perform any other duties beyond assisting the PIC with seeing and avoiding 

other air traffic and other ground based obstacles/obstructions, and will not be permitted to 

operate the camera or other instruments.

10. The PIC will be designated before the flight and will not be allowed to transfer his or her 

designation for the duration of the flight. The PIC will ensure that the VO can perform the 

functions prescribed in these conditions and the operating documents.

11. A briefing will be conducted in regard to the planned UA operations prior to each day’s 

activities. It will be mandatory that all personnel who will be performing duties in connection 

with the operations be present for this briefing. 

12. Prior to each flight, the PIC will inspect the UA, including the Ground Control Station, to 

ensure it is in a condition for safe flight. If the inspection reveals a condition that affects the 

safe operation of the UA, the PIC will not operate the UA until the necessary maintenance has 

been performed and the UA is found to be in a condition for safe flight. All maintenance and 

alterations will be properly documented in the aircraft records.

13. Petitioner will conduct a functional flight test on any UA that has undergone maintenance or 

alterations that affect the UA operation or flight characteristics, e.g. replacement of a flight 

critical component. The PIC who conducts the functional test flight will make an entry in the 

aircraft records. 

14. The petitioner will carry out its maintenance, inspections, and record keeping requirements, in 

accordance with the UA manufacturer’s aircraft/component, maintenance, overhaul, 

replacement, inspection, and life limit requirements set forth in the operating documents. 

Maintenance, inspection, alterations, and status of replacement/overhaul component parts will 

be noted in the aircraft records, including total time in service, description of work 

accomplished, and the signature of the authorized person returning the UA to service. The 

authorized person will make an entry in the aircraft record of the corrective action taken against 

discrepancies discovered between inspections.

15. The UA will be operated within visual line of sight (VLOS) of the PIC and VO at all times. 

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

corrective lenses. PIC and VO will at all times be able to communicate verbally. They will not 

be permitted to use electronic messaging or texting to communicate during flight operations. 

16. The PIC will not begin 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 prepare to 

land with at least 25% battery power remaining.

17. Actual total flight time for each operational flight will result in no less than a 25% battery 

reserve.

18. The UA will have the capability to abort a flight in case of unexpected obstacles or 

emergencies. 
10

19. The UA will be programmed so that if it loses communications or loses its GPS signal, it will 

return to a pre-determined location within the planned operating area and land or be recovered 

in accordance with the operating documents

20. If the UA and its radio control link disconnect during flight, the system’s failsafe protection 

will be triggered and the multirotor will return to home and land automatically, rather than 

flying off uncontrollably or landing at an unknown location. 

21. The operating documents required under 14 CFR §§ 91.9 and 91.203 will be maintained and 

available to the PIC at the Ground Control Station of the UA any time the UA is operating. 

These documents will be made available to the Administrator or any law enforcement official 

upon request. If a discrepancy exists between the conditions and limitations in the exemption 

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

limitations will take precedence and will be followed. Otherwise, the petitioner will follow the 

procedures outlined in its operating documents. If it updates or revises its operating documents, 

it will present updated and revised documents to the Administrator upon request. If the 

petitioner determines that any update or revision would affect the basis upon which the FAA 

granted the exemption, then the Petitioner will petition for an amendment to the grant of 

exemption. 

22. Petitioner will obtain written and/or oral permission from the landowners/authorized agents of 

the landowners over which flights will be conducted.

23. Petitioner will obtain all required permissions and permits from territorial, state, county or city 

jurisdictions, including local law enforcement, fire, or other appropriate governmental 

agencies. 

24. UA operations will not be conducted during night, as defined in 14 CFR § 1.1. All operations 

will be conducted under visual meteorological conditions (VMC). Flights will not be 

conducted under special visual flight rules (SVFR). 

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

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

Petitioner will request a Notice to Airman (NOTAM) not more than 72 hours in advance, but 

not less than 24 hours prior to the operation. All operations will be conducted in accordance 

with airspace requirements in the ATO issued COA, including class of airspace, altitude level 

and potential transponder requirements. 

26. The UA will not be operated 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 has been obtained, and the operation is conducted in accordance with a NOTAM 

as required by the operator’s COA. Any letter of agreement with the airport management will 

be made available to the Administrator upon request. 

27. The UA will 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. 
11

28. All operations shall be conducted in Class G airspace or as otherwise prescribed in an ATO 

issued COA. 

29. All aircraft operated in accordance with this exemption will be identified by serial number, 

registered in accordance with 14 CFR part 47, and have identification (N-Number) markings 

in accordance with 14 CFR part 45, Subpart C. Markings will be as large as practicable. 

30. Before conducting operations, petitioner will ensure that the radio frequency spectrum used 

for operation and control of the UA complies with the Federal Communications Commission 

(FCC) or other appropriate government oversight agency requirements. 

31. The UA will remain clear and yield the right of way to all manned aviation operations and 

activities at all times. 

32. The UA will not be operated by the PIC from any moving device or vehicle. 

33. Petitioner will conduct all flight operations at least 500 feet from all nonparticipating persons, 

vessels, vehicles, and structures unless one of the following three conditions is met:

a. Barriers or structures are present that sufficiently protect nonparticipating persons from the 

UA and/or debris in the event of an accident. The petitioner will 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, the PIC 

will ensure that flight operations cease immediately.

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.

c. Operations nearer to the PIC, VO, operator trainees or essential persons do not present an 

undue hazard to those persons per § 91.119(a).

34. Petitioner will report any incident, accident, or flight operation that transgresses the lateral or 

vertical boundaries of the operational area as defined by the applicable COA to the FAA's UAS 

Integration Office (AFS-80) within 24 hours. Petitioner will report accidents to the National 

Transportation Safety Board (NTSB) per instructions contained on the NTSB Web site: 

www.ntsb.gov. 

VI. Privacy

There is little concern that the proposed flights will cause invasions of privacy. All flights 

will occur over either (a) public rights of way where there is no expectation of privacy; or (b) over 

private property with permission of the landowner/authorized agent and consent of participating 

individuals.

If data collected is made available for public view, all images containing uninvolved 

persons will be blurred or blacked-out. No attempt will be made to identify any individuals filmed 

during the flights except in cases where they are trespassing upon or damaging customer property, 

or interfering with the petitioner’s or its customers’ operations.
12

VII. Public Interest and Safety

The planned UA use will increase ground safety for aerial photography and videography 

for the construction and real estate industries. This type of data collection has previously been 

performed by manned aircraft or by individuals on the ground. Both are more time consuming and

are more expensive than using UAs. Use of manned aircraft also poses enhanced risk to the pilot 

and onboard crew, who would be several hundred feet in the air. 

The enhanced safety and reduced environmental impact achieved using UAs and carrying 

no passengers or crew, rather than a manned aircraft of significantly greater mass, carrying crew 

in addition to flammable fuel, gives the FAA good cause to find that the UA operation enabled by 

this exemption is in the public interest.

Satisfaction of the criteria provided in Section 333 of the Reform Act of 2012 – size, 

weight, speed, operating capabilities, proximity to airports and populated areas and operation 

within visual line of sight and national security – provide more than adequate justification for the

grant of the requested exemption allowing commercial operation of petitioner’s UA for aerial 

photography and videography for the construction and real estate industries pursuant to 

JandDImages rules of operation.

The FAA has previously determined that using the DJI Inspire 1 family for aerial 

photography and videography for the construction and real estate industriesy is in the public 

interest in the following Exemption Nos.:

Exemption No. 11204 (aerial photography of... construction industry sites);

Exemption No. 11288 (construction... monitoring);

Exemption No. 11384 (construction applications such as... construction);

Exemption No. 11535 (aerial acquisitions of imagery in support of construction progress);

Exemption No. 11620 (aerial photography and videography for... construction industries);

Exemption No. 11644 (aerial video and photography of construction sites);

Exemption No. 11647 (aerial video and photography of construction sites);

Exemption No. 11702 (aerial videography and photography of construction sites);

Exemption No. 11712 (aerial video and photography of construction sites); and

Exemption No. 11714 (survey-grade construction mapping and monitoring).

The FAA has previously determined that using the DJI Inspire 1 family for aerial 

photography and videography for the construction and real estate industriesy is in the public 

interest in the following Exemption Nos.:

Exemption No. 11714 (real estate);

Exemption No. 11716 (aerial photography and videography of real property);

Exemption No. 11728 (aerial video and photography of... real estate);

Exemption No. 11750 (aerial video and photography of... real estate);

Exemption No. 11784 (aerial photography for... real estate);

Exemption No. 11790 (aerial photography and videography services for real estate);

Exemption No. 11792 (aerial videography and or photography for real estate);

Exemption No. 11821 (aerial real estate video and photography);

Exemption No. 11836 (aerial videography and photography of construction sites); and

Exemption No. 11843 (aerial photography and videography for real estate).
13

VIII. Regulations from Which Exemption is Requested

Appendix A: FARs as to which JandDImages wishes the same determination to be made as 

has been made previously.

FAR 

Provision

Applicable condition(s) in 

Section 5 of petition

FAA Exemption Decision

21(h) 1, 2, 3, 4, 5, 16, 25, 28, 29 Nos. 11252, 11396, 11467, 11745, 11797, 11905, 

11945, 12040, 12068, 12080, 12107, 12422, 12474, 

13365, 13366, 13933, 14026, 14194, 14195, 14196

43.7 13, 14 Nos. 11252, 11396, 11467, 11745, 11797, 11905, 

11945, 12040, 12068, 12080, 12107, 12422, 12474, 

13365, 13366, 13933, 14026, 14194, 14195, 14196

43.11 12 Nos. 11252, 11396, 11467, 11745, 11797, 11905, 

11945, 12040, 12068, 12080, 12107, 12422, 12474, 

13365, 13366, 13933, 14026, 14194, 14195, 14196

45.11 29 Nos. 11252, 11396, 11467, 11745, 11797, 11905, 

11945, 12040, 12068, 12080, 12107, 12422, 12474, 

13365, 13366, 13933, 14026, 14194, 14195, 14196

45.27 29 Nos. 11252, 11396, 11467, 11745, 11797, 11905, 

11945, 12040, 12068, 12080, 12107, 12422, 12474, 

13365, 13366, 13933, 14026, 14194, 14195, 14196

45.29 29 Nos. 11252, 11396, 11467, 11745, 11797, 11905, 

11945, 12040, 12068, 12080, 12107, 12422, 12474, 

13365, 13366, 13933, 14026, 14194, 14195, 14196

91.7(a) 12 Nos. 11252, 11396, 11467, 11745, 11797, 11905, 

11945, 12040, 12068, 12080, 12107, 12422, 12474, 

13365, 13366, 13933, 14026, 14194, 14195, 14196

91.9(b)(2) 22 Nos. 11252, 11396, 11467, 11745, 11797, 11905, 

11945, 12040, 12068, 12080, 12107, 12422, 12474, 

13365, 13366, 13933, 14026, 14194, 14195, 14196

91.9(c) 30 Nos. 11252, 11396, 11467, 11745, 11797, 11905, 

11945, 12040, 12068, 12080, 12107, 12422, 12474, 

13365, 13366, 13933, 14026, 14194, 14195, 14196

91.103(b)(2) 3, 9, 15, 16, 17, 18, 19, 20 Nos. 11252, 11396, 11467, 11745, 11797, 11905, 

11945, 12040, 12068, 12080, 12107, 12422, 12474, 

13365, 13366, 13933, 14026, 14194, 14195, 14196

91.105 6 Nos. 11252, 11396, 11467, 11745, 11797, 11905, 

11945, 12040, 12068, 12080, 12107, 12422, 12474, 

13365, 13366, 13933, 14026, 14194, 14195, 14196

91.109 7, 8 Nos. 11252, 11467, 11745, 11797, 11905, 11945, 

12040, 12068, 12422, 12474, 13365, 13366, 13933, 

14026, 14194, 14195, 14196

91.113(b) 3, 31 Nos. 11252, 11396, 11467, 11745, 11797, 11905, 

11945, 12040, 12068, 12080, 12107, 12422, 12474, 

13365, 13366, 13933, 14026, 14194, 14195, 14196
14

FAR 

Provision

Applicable condition(s) in 

Section 5 of petition

FAA Exemption Decision

91.119(c ) 4, 33 Nos. 11252, 11396, 11467, 11745, 11797, 11905, 

11945, 12040, 12068, 12080, 12107, 12422, 12474, 

13365, 13366, 13933, 14026, 14194, 14195, 14196

91.121 4 Nos. 11252, 11396, 11467, 11745, 11797, 11905, 

11945, 12040, 12068, 12080, 12107, 12422, 12474, 

13365, 13366, 13933, 14026, 14194, 14195, 14196

91.151(a) 16, 17 Nos. 11252, 11396, 11467, 11745, 11797, 11905, 

11945, 12040, 12068, 12080, 12107, 12422, 12474, 

13365, 13366, 13933, 14026, 14194, 14195, 14196

91.203 (a) 

and (b)

22 Nos. 11252, 11396, 11467, 11745, 11797, 11905, 

11945, 12040, 12068, 12080, 12107, 12422, 12474, 

13365, 13366, 13933, 14026, 14194, 14195, 14196

91.215 25, 26 Nos. 11252, 11396, 11467, 11745, 11797, 11905, 

11945, 12040, 12068, 12080, 12107, 12422, 12474, 

13365, 13366, 13933, 14026, 14194, 14195, 14196

91.403 12, 13, 14 Nos. 11252, 11396, 11467, 11745, 11797, 11905, 

11945, 12040, 12068, 12080, 12107, 12422, 12474, 

13365, 13366, 13933, 14026, 14194, 14195, 14196

91.405(a) 12, 13, 14 Nos. 11252, 11396, 11467, 11745, 11797, 11905, 

11945, 12040, 12068, 12080, 12107, 12422, 12474, 

13365, 13366, 13933, 14026, 14194, 14195, 14196

91.407(a)(1) 14 Nos. 11252, 11396, 11467, 11745, 11797, 11905, 

11945, 12040, 12068, 12080, 12107, 12422, 12474, 

13365, 13366, 13933, 14026, 14194, 14195, 14196

91.409(a)(1) 12, 13, 14 Nos. 11252, 11396, 11467, 11745, 11797, 11905, 

11945, 12040, 12068, 12080, 12107, 12422, 12474, 

13365, 13366, 13933, 14026, 14194, 14195, 14196

91.409(a)(2) 12, 13, 14 Nos. 11252, 11396, 11467, 11745, 11797, 11905, 

11945, 12040, 12068, 12080, 12107, 12422, 12474, 

13365, 13366, 13933, 14026, 14194, 14195, 14196

91.417(a) 12, 13, 14 Nos. 11252, 11396, 11467, 11745, 11797, 11905, 

11945, 12040, 12068, 12080, 12107, 12422, 12474, 

13365, 13366, 13933, 14026, 14194, 14195, 14196

91.417(b) 12, 13, 14 Nos. 11252, 11396, 11467, 11745, 11797, 11905, 

11945, 12040, 12068, 12080, 12107, 12422, 12474,

13365, 13366, 13933, 14026, 14194, 14195, 14196