1 

UNITED STATES OF AMERICA 

DEPARTMENT OF TRANSPORTATION 

FEDERAL AVIATION ADMINISTRATION 

WASHINGTON, DC 

Regulatory Docket No. _______________ 

IN THE MATTER OF THE PETITION FOR EXEMPTION OF: 

Aerospace Access Corporation

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)

Aerospace Access Corporation 

Marcello Mattos 

President 

Address: 3387 Merrick Ct., Margate - FL 33063 

Phone: 954-889-6355 / Fax: 954-889-3758 

Email: UAV@aerospaceaccess.com 
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TABLE OF CONTENTS 

GLOSSARY OF ABBREVIATIONS............................................................................................. 4 

 

SUMMARY ...... ............................................................................................................................... 5 

INTRODUCTION AND INTERESTS OF THE PETITIONER ................................................ 5 

 

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

BASIS FOR PETITION .................................................................................................................. 6 

A. Name and address of the petitioner. .......................................................................................... 7 

B. The specific sections of 14 C.F.R. from which Aerospace Access seeks exemption. ............. 7 

C. The extent of relief Aerospace Access seeks and the reason Aerospace Access seeks the relief. 

........................................................................................................................................................... 10 

D. The reasons why granting Aerospace Access request would be in the public interest ....... 12 

E. The reasons why granting the exemption would not adversely affect safety ...................... 14 

F. The rules from which Aerospace Access seeks exemption .................................................... 25 

G. Any additional information, views, or arguments available to support request. ............. 25 

CONCLUSION ............................................................................................................................... 26 

APPENDICES ................................................................................................................................ 27 

 APPENDIX – A: DJI Inspire 1 Technical Specifications ......................................................... 28 

 APPENDIX – B: DJI Inspire 1 Manufacturer’s User Manual ................................................ 29 

 

 APPENDIX – C: DJI Inspire 1 Manufacturer’s Maintenance Manual .................................. 30 

 APPENDIX – D: DJI Inspire 1 Manufacturer’s Safety Guidelines ......................................... 31 
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4 

 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

Aerospace Access Corporation 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 Aerospace Access to operate an 

Unmanned Aircraft System (UAS) for the commercial purpose of conducting aerial surveying, 

remote sensing, precision agriculture, real estate marketing and inspection, motion picture aerial 

filmmaking and photography, private event photography, utility system inspections and patrolling, 

construction site inspection and monitoring, wildlife and forestry monitoring, educational and 

research operations, flare stack inspection, pipeline inspection and patrolling over certain areas of the 

United States and Brazil. 

 

INTRODUCTION AND INTERESTS OF THE PETITIONER

Aerospace Access Corporation, hereto referred in this document as Aerospace Access is seeking to 

offer possibly all the UAS services mentioned in the summary above as part of new business 

opportunity. Aerospace Access was founded in 2008 in the state of Florida as a commercial aviation 

parts supplier, with nearly a decade of experience with FAA and EASA approved parts and 

standards. Aerospace Access has established good relationships in the aviation industry and is among 

the fastest growing companies in South Florida serving end-users worldwide. The objective of 

Aerospace Access UAS operations is to provide high quality imaging for a variety of commercial, 

public, and residential uses, specifically targeting: 

 Aerial Surveying 

 Remote Sensing 

 Precision Agriculture 

 Real Estate Marketing and Inspection 

 Motion Picture Aerial Filmmaking and Photography 

 Private Event Photography 

 Utility System Inspections and Patrolling 

 Construction Site Inspection and Monitoring 

 Wildlife and Forestry Monitoring 

 Educational and Research Operations 

 Flare Stack Inspection 

 Pipeline Inspection and Patrolling 

BACKGROUND

Unmanned Aircraft Systems: DJI Inspire 1 UAS

Aerospace Access seeks an exemption to operate DJI systems for compensation or hire within the 

NAS and the Brazil if permitted by National Civil Aviation Agency of Brazil (ANAC). The DJI 

Inspire 1 vertical takeoff and landing (VTOL) Unmanned Aircraft (UA) with a Ground Control 

Station (GCS) utilizes electronic tablet or smart phone systems. The DJI Inspire 1 has a maximum 

gross weight of 6 pounds 7.5 ounces, a length of 17.3 inches, width of 17.7 inches, height of 11.8 

inches, and a maximum speed of approximately 42 knots. The DJI Inspire 1 UA is equipped with 

four main rotors; driven by Lithium Polymer battery powered electric motors. 
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The DJI Inspire 1 UA that will be operated by Aerospace Access will be registered in accordance 

with 49 U.S.C. 44103, Registration of Aircraft, as well as 14 C.F.R Part 47, Aircraft Registration, 

and marked in accordance with 14 C.F.R. Part 45, Identification and Registration Marking. 

BASIS FOR PETITION

Petitioner, Aerospace Access, 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, Aerospace Access 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, Aerospace Access 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. 

 

Aerospace Access submits that the requested relief is proper since an equivalent level of safety will 

be ensured. Aerospace Access 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, Aerospace Access 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 Aerospace Access 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. 

 

Aerospace Access seeks relief from Section 91.7(a), entitled Civil aircraft airworthiness, because the 

DJI Inspire 1 UAS do not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, 

Subpart H. As such, Aerospace Access submits that it will ensure that the DJI Inspire 1 UAS are in 

an airworthy condition, prior to every flight, by determining that the UAS are in compliance with the 

operating documents (i.e., Monthly Maintenance Log, and DJI Inspire 1 Instruction Manual), and 

that the aircraft are in a condition for safe flight. 

 

Aerospace Access 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 1 UA will be provided to the PIC via Global 

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

downlinks from the UA to the GCS for active monitoring of the flight path. This altitude information, 
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combined with Aerospace Access’ 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, Aerospace Access seeks an exemption from the requirements of Section 91.151(b), 

entitled Fuel requirements for flight in VFR conditions. Aerospace Access submits that safety will 

not be affected by operation of the DJI Inspire 1 UA during daylight hours in visual meteorological 

conditions (VMC) under visual flight rules (VFR), with enough battery power to fly for a total 

duration of approximately 13.5 minutes to the first point of intended landing and, assuming normal 

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

 

In accordance with 14 C.F.R. § 11.81, Aerospace Access 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: 

 

 Aerospace Access Corporation 

 Marcello Mattos 

 3387 Merrick Ct. 

 Margate, FL 33063 

 Phone: 954-889-6355 

 Fax: 954-889-3758 

 Mobile: 954-643-2512 

 Email: UAV@aerospaceaccess.com 

 

B. The specific sections of 14 C.F.R. from which Aerospace Access seeks exemption. 

 1. Aerospace Access 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. Aerospace Access 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. 
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 3. Aerospace Access 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. Aerospace Access seeks exemption from the requirements of Section 

 91.151(b). 

 Section 91.151, entitled Fuel requirements for flight in VFR conditions, subsection 

 (b), states the following: 

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

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

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

 fly after that for at least 20 minutes. 

 5. Aerospace Access 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. Aerospace Access 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. Aerospace Access seeks exemption from the requirements of Sections 

 91.409(a)(1) and 91.409(a)(2). 
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 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. Aerospace Access seeks exemption from the requirements of Sections 

 91.417(a) and 91.417(b). 

 

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

 following: 

 (a) Except for work performed in accordance with §§ 91.411 and 91.413, each 

 registered owner or operator shall keep the following records for the periods 

 specified in paragraph (b) of this section: 

 (1) Records of the maintenance, preventive maintenance, and alteration 

 and records of the 100-hour, annual, progressive, and other required 

 or approved inspections, as appropriate, for each aircraft (including 

 the airframe) and each engine, propeller, rotor, and appliance of an 

 aircraft. The records must include-- 

 (i) A description (or reference to data acceptable to the 

 Administrator) of the work performed; and 

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

 (iii) The signature and certificate number of the person approving 

 the aircraft for return to service. 

 (2) Records containing the following information: 

 (i) The total time in service of the airframe, each engine, each 

 propeller, and each rotor. 

 (ii) The current status of life-limited parts of each airframe, 

 engine, propeller, rotor, and appliance. 

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

 retained until the work is repeated or superseded by other work or for 

 1 year after the work is performed. 

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

 retained and transferred with the aircraft at the time the aircraft is 

 sold. 

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

 43.11 of this chapter shall be retained until the defects are repaired 

 and the aircraft is approved for return to service. 

C. The extent of relief Aerospace Access seeks and the reason Aerospace Access 

 seeks the relief. 

 1. Extent of relief Aerospace Access seeks and the reason Aerospace 

 Access 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, Aerospace Access submits that an equivalent level of 

 safety will be maintained because no PIC will be allowed to operate the DJI Inspire 1 

 UAS unless that PIC has met certain flight-hour and currency requirements, 

 demonstrating that the PIC is able to safely operate either the DJI Inspire 1 UAS in a 

 manner consistent with the operations specifications as described in this exemption, 

 including evasive and emergency maneuvers, as well as maintaining appropriate 

 distances from people, vessels, vehicles and structures. 

 

 Further, Aerospace Access 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 

 Aerospace Access business; and (2) will not carry passengers or property for 

 compensation or hire. 

 2. Extent of relief Aerospace Access seeks and the reason Aerospace Access 

 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 Aerospace Access to determine that the DJI Inspire 1 UAS is 

 in airworthy condition prior to every flight by ensuring that the UAS is in compliance 
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 with the operating documents (i.e., the Aerospace Access Aerial Operations Manual, 

 Monthly Maintenance Log, and DJI Inspire 1 Instruction Manual). 

 

 Aerospace Access 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, Aerospace Access 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 are in condition for safe flight, as stated in the 

 conditions and limitations below. 

 3. Extent of relief Aerospace Access seeks and the reason Aerospace Access 

 seeks relief from Section 91.121. 

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

 flight operations of the DJI Inspire 1 UAS, which utilize a barometric pressure 

 sensor, GPS equipment, and a radio communications telemetry data link to downlink 

 altitude information from the UA to the PIC at the ground control station (GCS). 

 Since the FAA requires that any altitude information concerning UAS operations be 

 reported to air traffic control (ATC) in feet above ground level (AGL), Aerospace 

 Access seeks the requested relief because the DJI Inspire 1 UA’s altimeter may be set 

 on the ground to zero feet AGL, rather than the local barometric pressure or field 

 altitude, before each flight. 

 

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

 91.121 is sought to the extent necessary to comply with the applicable conditions and 

 limitations stated below. As more fully set forth herein, an equivalent level of safety 

 will be maintained since the DJI Inspire 1 UA are equipped with a barometric 

 pressure sensor and GPS equipment, which automatically ensures that a ground level 

 pressure setting will be established prior to each flight, and provides the PIC with 

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

 4. Extent of relief Aerospace Access seeks and the reason Aerospace Access 

 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 UA 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. Aerospace Access seeks the requested relief because without an 

 exemption from Section 91.151(b), the flight time duration of the battery powered 

 DJI Inspire 1 UA will severely constrain the practicality of any aerial video or still 

 photo flight operations that Aerospace Access proposes to conduct pursuant to this 

 Petition. 

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

 UAS, the DJI Inspire 1 operating documents, and Aerospace Access proposed 
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 operating limitations, ensure that Aerospace Access will safely operate the battery 

 powered DJI Inspire 1 UA during daylight hours in visual meteorological conditions 

 (VMC), under visual flight rules (VFR), with enough battery power to fly for a total 

 duration of 13.5 minutes to the first point of intended landing and, assuming normal 

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

 5. Extent of relief Aerospace Access seeks and the reason Aerospace Access 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, Aerospace Access 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 meet 

 the conditions of FMRA Section 333 for operation without an airworthiness 

 certificate. Accordingly, Aerospace Access 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 

 Aerospace Access Aerial Operations Manual, Monthly Maintenance Log, and DJI 

 Inspire 1 Instruction Manual). Furthermore, Aerospace Access will document and 

 maintain all maintenance records for the DJI Inspire 1 UAS. 

D. The reasons why granting Aerospace Access 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 Aerospace Access to 

 safely, efficiently, and economically perform aerial surveying, remote sensing, precision 

 agriculture, real estate marketing and inspection, motion picture aerial filmmaking and 

 photography, private event photography, utility system inspections and patrolling, 

 construction site inspection and monitoring, wildlife and forestry monitoring, educational and 

 research operations, flare stack inspection, pipeline inspection and patrolling over certain 

 areas of the United States and Brazil. 

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

 public safety by performing inspections transportation infrastructures, monitor forests 

 and wildlife, reduce pollution and provide significant benefits to the economy. Notably, 

 the benefits of Aerospace Access’ 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 UA are battery powered and serve as a safe, efficient, and 

 economical alternative to the manned aircraft traditionally utilized to obtain aerial 

 imagery. By reducing the amount of manned aircraft needed to perform aerial 

 acquisitions, an exemption allowing the use of a DJI Inspire 1 UAS would reduce the 

 amount of manned aircraft in the NAS, reduce noise and air pollution, as well as 

 increase the safety of life and property in the air and on the ground. 
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 Furthermore, by reducing the number of manned aircraft operating in the NAS, 

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

 The DJI Inspire 1 UA does not require an airport to takeoff or land. Likewise, a 

 reduction of manned aircraft conducting aerial video and photography missions 

 would result in fewer 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 flight 

 operations. By using battery power and electric motors, the DJI Inspire 1 UAS 

 produce no air pollution, and is the most viable environmentally conscious alternative 

 to the cabin class, six cylinder internal combustion engine aircraft that are typically 

 utilized for aerial video and photography, while burning approximately 20-30 gallons 

 per hour of leaded aviation fuel. The DJI Inspire 1 UA, while reducing the carbon 

 footprint of aerial acquisitions, also eliminates noise pollution, as the UA are 

 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 UA (weighing approximately 6 pounds 7.5 ounces, at 

 maximum gross weights with length of 17.3 inches, width of 17.7 inches, and with no 

 fuel on board), has less physical potential for collateral damage to life and property 

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

 similar operations (weighing approximately 6,000 pounds with a wingspan of 

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

 3. Increased safety in highways and protection of forests and wildlife. 

 The use of the DJI Inspire 1 UAS is more affordable than the use of traditional 

 manned aircraft during inspections of bridges, highways and other infrastructure, a 

 reduced cost would be an incentive to increased frequency of inspections and less 

 rush while performing the task. The silent nature of the DJI Inspire 1 UAS also helps 

 monitor wildlife without any disturbance and in countries like Brazil that suffers with 

 extraction of wood, it would help monitor any changes in the landscape and even 

 catch illegal activities or fire started by farmers illegally to increase pasture and 

 agricultural land. 

 4. 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 are also an economical 

 alternative to using manned aircraft to conduct similar aerial operations. As such, 
14 

 operation of the DJI Inspire 1 UAS will allow United States based companies, like 

 Aerospace Access, 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 Aerospace Access, 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. 

 5. There are no privacy issues. 

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

 for decades, Aerospace Access’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 Aerospace Access 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. 

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 Aerospace Access seeks exemption. 

 1. Reasons why the DJI Inspire 1 UA meet the conditions of the FAA 

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

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

 the unmanned aircraft and its operation, Aerospace Access operation of the DJI 

 Inspire 1 UAS meet the conditions of FMRA Section 333, and will not require an 

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

 

 Section 333 provides authority for a UAS to operate without airworthiness 

 certification and sets forth requirements for considering whether a UAS will create a 

 hazard to users of the NAS or the public, or otherwise pose a threat to national 

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

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

 later than 180 days after the date of enactment of this Act, the Secretary of 
15 

 Transportation shall determine if certain unmanned aircraft systems may 

 operate safely in the national airspace system before completion of the plan 

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

 by section 334 of this Act. 

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

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

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

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

 populated areas, and operation within visual line of sight do not 

 create a hazard to users of the national airspace system or the public 

 or pose a threat to national security; and 

 (2) whether a certificate of waiver, certificate of authorization, or 

 airworthiness certification under section 44704 of title 49, United 

 States Code, is required for the operation of unmanned aircraft 

 systems identified under paragraph (1). 

 (c) Requirements for Safe Operation.--If the Secretary determines under this 

 section that certain unmanned aircraft systems may operate safely in the 

 national airspace system, the Secretary shall establish requirements for the 

 safe operation of such aircraft systems in the national airspace system. 

In seeking this exemption, Aerospace Access 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, attached hereto as 

 Appendix 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 pages 45- 

 50 of the DJI Inspire 1 User Manuals, attached hereto as Appendix B. 
16 

 iii. The DJI Inspire 1 UAS are designed for automatic return to 

 home point or hover in the event of loss of the control link 

 or navigation. 

 When the Control Link is lost, the DJI Inspire 1 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 

 shutdown. 

 A complete description of the Failsafe Functions of the DJI Inspire 1 

 are set forth at pages 13 through 15 in the DJI Inspire 1 User Manual, 

 attached hereto as Appendix 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 47 of the DJI Inspire 1 User Manual. DJI Inspire 1 User 

 Manuals are attached hereto as Appendix B. 

 b. Flight operations of the DJI Inspire 1 UAS is limited to the line of 

 sight of a certificated pilot in command with a safety observer. 

 Aerospace Access will only utilize certificated operators to act as a pilot in 

 command (PIC) of the DJI Inspire 1 UAS. Additionally, a safety observer 

 will assist all pilots during flight time. 

 c. Flights of DJI Inspire 1 UAS will be conducted pursuant to specific 

 operating limitations. 

 In seeking this exemption, Aerospace Access proposes to commercially 

 operate the 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. 
17 

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

 knots. 

 4. The UA must be operated at an altitude of no more than 500 feet 

 above ground level (AGL), as indicated by the procedures specified in 

 the operating documents unless a special request is made and 

 approved by ATC. All altitudes reported to ATC must be in feet 

 AGL. 

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

 PIC at all times. This requires the PIC to be able to use human vision 

 unaided by any device other than corrective lenses, as specified on the 

 PIC’s FAA-issued airman medical certificate. 

 6. The use of first person view (FPV) by the PIC or safety observer (SO) 

 is not permitted. 

 7. All operations must utilize a safety observer (SO). The SO may be 

 used to satisfy the VLOS requirement as long as the PIC always 

 maintains VLOS capability. The SO and PIC must be able to 

 communicate verbally at all times. Electronic messaging or texting is 

 not permitted during flight operations. The PIC must be designated 

 before the flight and cannot transfer his or her designation for the 

 duration of the flight. The PIC must ensure that the SO can perform 

 the functions prescribed in the operating documents. 

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

 with seeing and avoiding other air traffic and other ground based 

 obstacles/obstructions and is not permitted to operate the camera or 

 other instruments. 

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

 accessible during UAS operations and made available to the 

 Administrator upon request. If a discrepancy exists between the 

 conditions and limitations contained in the grant of exemption and the 

 procedures outlined in the operating documents, the conditions and 

 limitations contained in the grant of exemption take precedence and 

 must be followed. Otherwise, the operator must follow the procedures 

 as outlined in its operating documents. The operator may update or 

 revise its operating documents. It is the operator’s responsibility to 

 track such revisions and present updated and revised documents to the 

 Administrator upon request. The operator must also present updated 

 and revised documents if it petitions for extension or amendment to 

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

 revision would affect the basis upon which the FAA granted the 

 exemption, then the operator must petition for amendment to its grant 

 of exemption. The FAA’s UAS Integration Office (AFS-80) may be 

 contacted if questions arise regarding updates or revisions to the 

 operating documents. 
18 

 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 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 
19 

 conducted during dedicated training sessions. During training, 

 proficiency, and experience-building flights, all persons not essential 

 for flight operations are considered nonparticipants, and the PIC must 

 operate the UA with appropriate distance from nonparticipants in 

 accordance with 14 C.F.R. § 91.119. 

 19. UAS operations may not be conducted during night, as defined in 14 

 C.F.R. § 1.1. All operations must be conducted under visual 

 meteorological conditions (VMC). If flight at night is required, a 

 special request will be made at the FAA office closest to proposed 

 area of operations. Flights under special visual flight rules (SVFR) are 

 not authorized. 

 20. The UA may not operate within 5 nautical miles of an airport 

 reference point as denoted on a current FAA-published aeronautical 

 chart unless a letter of agreement with that airport’s management is 

 obtained, and the operation is conducted in accordance with a 

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

 with the airport management must be made available to the 

 Administrator upon request. 

 21. The UA may not be operated less than 500 feet below or less than 

 2,000 feet horizontally from a cloud or when visibility is less than 3 

 statute miles from the PIC. 

 22. If the UA loses communications or loses its GPS signal, it must return 

 to a pre- determined location within the planned operating area and 

 land or be recovered in accordance with the operating documents. 

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

 emergencies in accordance with the operating documents. 

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

 wind and forecast weather conditions) there is enough power to fly at 

 normal cruising speed to the intended landing point and land the UA 

 with 25% battery power remaining. 

 25. The operator must obtain an Air Traffic Organization (ATO) issued 

 Certificate of Waiver or Authorization (COA) prior to conducting any 

 operations under the grant of exemption. This COA will also require 

 the operator to request a Notice to Airman (NOTAM) not more than 

 72 hours in advance, but not less than 48 hours prior to the operation. 

 All operations shall be conducted in accordance with airspace 

 requirements in the ATO issued COA including class of airspace, 

 altitude level and potential transponder requirements. 

 26. All aircraft operated in accordance with the exemption must be 

 identified by serial number, registered in accordance with 14 C.F.R. 

 part 47, and have identification (N- Number) markings in accordance 
20 

 with 14 C.F.R. part 45, Subpart C. Markings must be as large as 

 practicable. 

 27. Before conducting operations, the radio frequency spectrum used for 

 operation and control of the UA must comply with the Federal 

 Communications Commission (FCC) or other appropriate government 

 oversight agency requirements. 

 28. The documents required fewer than 14 C.F.R. 91.9 and 91.203 must 

 be available to the PIC at the Ground Control Station of the UAS any 

 time the UAS is operating. These documents must be made available 

 to the Administrator or any law enforcement official upon request. 

 29. The UA must remain clear and yield the right of way to all manned 

 aviation operations and activities at all times. 

 30. The UAS may not be operated by the PIC from any moving device or 

 vehicle. 

 31. Flight operations must be conducted at least 500 feet from all 

 nonparticipating persons (persons other than the PIC, SO, operator 

 trainees or essential persons), vessels, vehicles, and structures unless: 

a. Barriers or structures are present that sufficiently protect 

nonparticipating persons from the UA and/or debris in the event 

of an accident. The operator must ensure that nonparticipating 

persons remain under such protection. If a situation arises where 

nonparticipating persons leave such protection and are within 500 

feet of the UA, flight operations must cease immediately and/or; 

b. The aircraft is operated near vessels, vehicles or structures where 

the owner/controller of such vessels, vehicles or structures has 

granted permission and the PIC has made a safety assessment of 

the risk of operating closer to those objects and determined that it 

does not present an undue hazard, and; 

c. Operations nearer to the PIC, SO, operator trainees or essential 

persons do not present an undue hazard to those persons per § 

91.119(a). 

 32. All operations shall be conducted over private or controlled-access 

 property with permission from the land owner/controller or authorized 

 representative. Permission from land owner/controller or authorized 

 representative will be obtained for each flight to be conducted. 

 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 
21 

 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. 

 Aerospace Access 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 Aerospace Access’ 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, 

 Aerospace Access submits that the additional manned airmanship experience of a 

 commercially certificated pilot would not correlate to the airmanship skills necessary 

 for Aerospace Access’ specific proposed flight operations. 

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

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

 Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 

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

 Aerospace Access 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 Aerospace Access’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), 
22 

 the PIC must have accumulated and logged, in a manner consistent with 14 

 CFR 61.51(b), 25 hours of total time as a UAS rotorcraft pilot including at 

 least 10 hours logged as a UAS pilot with a multi-rotor UAS. Prior to 

 operations under Exemption No. 11062, the PIC must also have accumulated 

 and logged a minimum of 5 hours as a UAS pilot operating the same make 

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

 clarification, the FAA considers these minimum hour requirements to be 

 inclusive rather than additive; i.e. 5 hours make and model time may be 

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

 in the total 25 hours of UAS rotorcraft time. In addition to the hour 

 requirements, the PIC must accomplish 3 takeoffs and landings in the 

 preceding 90 days (for currency purposes). The FAA finds that at a minimum, 

 the flight-hour requirements in Exemption No. 11062 are appropriate to 

 practice and build proficiency in the skills necessary to safely conduct the 

 petitioner’s proposed operations. The FAA also finds that prior documented 

 flight experience that was obtained in compliance with applicable regulations 

 would satisfy this requirement. Training, proficiency, and experience- 

 building flights can also be conducted under the grant of exemption to 

 accomplish the required flight time. During training, proficiency, and 

 experience-building flights the PIC is required to operate the UA with 

 appropriate distances in accordance with 14 C.F.R 91.119. 

 Exemption No. 11138 at page 15. 

 Accordingly, Aerospace Access 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, Aerospace Access 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 UA will be provided to the PIC 

 via GPS equipment and a radio communications telemetry data link, which 
23 

 downlinks from the UA to the GCS for active monitoring of the flight path and 

 altitude. This altitude information, combined with Aerospace Access’s operation of 

 the DJI Inspire 1 UA within visual line of sight, at or below 500 feet AGL, will 

 ensure a level of safety equivalent to Section 91.121. The altitude information will be 

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

 altitude initiation point is automatically established by the UAS at ground level. 

 The FAA has previously granted relief from Section 91.121 specific to UAS, in 

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

 Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11112, 

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

 5. Reasons why an exemption from the requirements of Section 91.151(b) would 

 not adversely affect safety. 22 

 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, Aerospace Access will 

 ensure that it will safely operate the battery powered DJI Inspire 1 UA 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 provide audible and visual warnings to the PIC at the GCS when the UA 

 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). 

 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. 
24 

 In seeking this exemption, Aerospace Access 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 Aerospace Access 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 Aerospace 

 Access Operations Manual, Monthly Maintenance Log, and the DJI Inspire 1 

 Instruction Manual). Furthermore, Aerospace Access 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, Aerospace Access will maintain the equivalent level of safety established 

 by Sections 91.405(a), 91.409(a)(1), and 91.409(a)(2). A copy of the DJI Inspire 1 

 User Manuals is attached hereto as Appendix B; a copy of the DJI Inspire 1 UAS 

 Maintenance Manual and Maintenance Log is attached hereto as Appendix C and E, 

 respectively. 

 Likewise, the exemption sought will not adversely affect safety because Aerospace 

 Access 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 Aerospace Access’s proposed operating limitations, the operating 

 documents, and the technical aspects of the DJI Inspire 1 UAS, Aerospace Access 

 submits that safety will not be adversely affected by granting exemption from 14 

 C.F.R. Sections 91.405(a), 91.407(a)(1) and (a)(2), 91.409(a)(2), and 91.417(a) and 

 (b). The FAA has previously granted relief specific to UAS in circumstances similar, 

 in all material respects, to those presented herein (e.g. Exemption Nos. 11062, 11063, 

 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112, 11136, 11138, 11150, 

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

 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, Aerospace Access 

 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), 
25 

 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 Aerospace Access intended operation of the DJI 

 Inspire 1 UAS, which contain such safety standards that the Administrator finds 

 necessary to establish a level of safety equivalent to that established by 14 C.F.R. Part 

 21, Subpart H, and 14 C.F.R Sections 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 

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

 F. A summary that can be published in the federal register, stating: The rules from 

 which Aerospace Access seeks exemption: 

 Aerospace Access 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 Aerospace Access seeks: 

 This exemption will permit Aerospace Access to commercially operate an Unmanned 

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

 over certain areas of the United States and Brazil. 

 G. Any additional information, views, or arguments available to support Aerospace 

 Access’ request. 
26 

 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, Aerospace Access’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, Aerospace Access 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. 

 If approved we would like to request the right to exercise the privileges of operating 

 our UAS outside the United States under § 11.83; specifically in Brazil, if permitted 

 by National Civil Aviation Agency of Brazil (ANAC). They are currently defining 

 rules and restrictions and Brazil is a vast country that will have a high demand in 

 agriculture and the public will benefit from infra-structure inspections for safety and 

 all the above mentioned benefits applied here in the United States. We understand 

 that we must be compliant with the Standards of the International Civil Aviation 

 Organization (ICAO) and ANAC. 

CONCLUSION

 As set forth herein, Aerospace Access 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 of the public, by allowing Aerospace Access 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, Aerospace Access 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 Aerospace Access to operate the DJI Inspire 1 UAS 

 commercially for the purpose of conducting aerial video and photography over certain areas 

 of the United States and Brazil. 

 

 

 

 _________________________ 

 Marcello Mattos - President 

 Aerospace Access Corporation 
27 

 APPENDICES

APPENDIX – A: DJI Inspire 1 Technical Specifications 

APPENDIX – B: DJI Inspire 1 Manufacturer’s User Manual 

APPENDIX – C: DJI Inspire 1 Manufacturer’s Maintenance Manual 

APPENDIX – D: DJI Inspire 1 Manufacturer’s Safety Guidelines 
28 

APPENDIX – A: DJI Inspire 1 Technical Specifications
29 

APPENDIX – B: DJI Inspire 1 Manufacturer’s User Manual
30 

APPENDIX – C: DJI Inspire 1 Manufacturer’s Maintenance Manual
31 

APPENDIX – D: DJI Inspire 1 Manufacturer’s Safety Guidelines