July 24, 2015

Exemption No. 12143

Regulatory Docket No. FAA–2015–1544

Mr. Steven Myles Rothacker

Founder

Atlanta Marketing Professionals

1420 Cresthaven Lane, Northwest

Lawrenceville, GA 30043

Dear Mr. Rothacker:

This letter is to inform you that we have granted your request for exemption. It transmits our 

decision, explains its basis, and gives you the conditions and limitations of the exemption, 

including the date it ends.

By letter dated April 24, 2015, you petitioned the Federal Aviation Administration (FAA) on 

behalf of Atlanta Marketing Professionals (hereinafter petitioner or operator) for an 

exemption. The petitioner requested to operate an unmanned aircraft system (UAS) to 

conduct aerial imaging, videography, surveying, and inspections.

See Appendix A for the petition submitted to the FAA describing the proposed operations and 

the regulations that the petitioner seeks an exemption.

The FAA has determined that good cause exists for not publishing a summary of the petition 

in the Federal Register because the requested exemption would not set a precedent, and any 

delay in acting on this petition would be detrimental to the petitioner.

Airworthiness Certification

The UAS proposed by the petitioner is a DJI Inspire 1.

The petitioner requested relief from 14 CFR part 21, Certification procedures for products 

and parts, Subpart H—Airworthiness Certificates. In accordance with the statutory criteria 

provided in Section 333 of Public Law 112−95 in reference to 49 U.S.C. § 44704, and in 
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consideration of the size, weight, speed, and limited operating area associated with the 

aircraft and its operation, the Secretary of Transportation has determined that this aircraft 

meets the conditions of Section 333. Therefore, the FAA finds that the requested relief from 

14 CFR part 21, Certification procedures for products and parts, Subpart H—Airworthiness 

Certificates, and any associated noise certification and testing requirements of part 36, is 

not necessary.

The Basis for Our Decision

You have requested to use a UAS for aerial data collection1. The FAA has issued grants of 

exemption in circumstances similar in all material respects to those presented in your petition. 

In Grants of Exemption Nos. 11062 to Astraeus Aerial (see Docket No. FAA−2014−0352), 

11109 to Clayco, Inc. (see Docket No. FAA−2014−0507), 11112 to VDOS Global, LLC (see

Docket No. FAA−2014−0382), and 11213 to Aeryon Labs, Inc. (see Docket No. 

FAA−2014−0642), the FAA found that the enhanced safety achieved using an unmanned 

aircraft (UA) with the specifications described by the petitioner and carrying no passengers or 

crew, rather than a manned aircraft of significantly greater proportions, carrying crew in 

addition to flammable fuel, gives the FAA good cause to find that the UAS operation enabled 

by this exemption is in the public interest.

Having reviewed your reasons for requesting an exemption, I find that—

 They are similar in all material respects to relief previously requested in Grant of 

Exemption Nos. 11062, 11109, 11112, and 11213;

 The reasons stated by the FAA for granting Exemption Nos. 11062, 11109, 11112, and 

11213 also apply to the situation you present; and 

 A grant of exemption is in the public interest.

Our Decision

In consideration of the foregoing, I find that a grant of exemption is in the public interest. 

Therefore, pursuant to the authority contained in 49 U.S.C. 106(f), 40113, and 44701, 

delegated to me by the Administrator, Atlanta Marketing Professionals is granted an 

exemption from 14 CFR §§ 61.23(a) and (c), 61.101(e)(4) and (5), 61.113(a), 61.315(a), 

91.7(a), 91.119(c), 91.121, 91.151(a)(1), 91.405(a), 91.407(a)(1), 91.409(a)(1) and (2), and 

91.417(a) and (b), to the extent necessary to allow the petitioner to operate a UAS to perform 

aerial data collection. This exemption is subject to the conditions and limitations listed 

below.

 

1 Aerial data collection includes any remote sensing and measuring by an instrument(s) aboard the UA. 

Examples include imagery (photography, video, infrared, etc.), electronic measurement (precision surveying, RF 

analysis, etc.), chemical measurement (particulate measurement, etc.), or any other gathering of data by 

instruments aboard the UA.
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Conditions and Limitations

In this grant of exemption, Atlanta Marketing Professionals is hereafter referred to as 

the operator.

Failure to comply with any of the conditions and limitations of this grant of exemption will be 

grounds for the immediate suspension or rescission of this exemption.

1. Operations authorized by this grant of exemption are limited to the DJI Inspire 1 when 

weighing less than 55 pounds including payload. Proposed operations of any other 

aircraft will require a new petition or a petition to amend this exemption.

2. Operations for the purpose of closed-set motion picture and television filming are 

not permitted. 

3. The UA may not be operated at a speed exceeding 87 knots (100 miles per hour). The 

exemption holder may use either groundspeed or calibrated airspeed to determine 

compliance with the 87 knot speed restriction. In no case will the UA be operated at 

airspeeds greater than the maximum UA operating airspeed recommended by the 

aircraft manufacturer.

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

(AGL). Altitude must be reported in feet AGL.

5. The UA 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 or 

U.S. driver’s license.

6. All operations must utilize a visual observer (VO). The UA must be operated within 

the visual line of sight (VLOS) of the PIC and VO at all times. The VO may be used 

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

capability. The VO 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 VO can perform the duties 

required of the VO.

7. This exemption and all documents needed to operate the UAS and conduct its 

operations in accordance with the conditions and limitations stated in this grant of 

exemption, are hereinafter referred to as the operating documents. The operating 

documents must be accessible during UAS operations and made available to the 

Administrator upon request. If a discrepancy exists between the conditions and 

limitations in this exemption and the procedures outlined in the operating documents, 
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the conditions and limitations herein 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 or any law enforcement official upon request. The 

operator must also present updated and revised documents if it petitions for extension 

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

or revision would affect the basis upon which the FAA granted this exemption, then 

the operator must petition for an 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.

8. 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 prior to conducting further operations under this exemption. 

Functional test flights may only be conducted by a PIC with a VO and must remain at 

least 500 feet from other people. The functional test flight must be conducted in such 

a manner so as to not pose an undue hazard to persons and property.

9. The operator is responsible for maintaining and inspecting the UAS to ensure that it is 

in a condition for safe operation.

10. Prior to each flight, the PIC must conduct a pre-flight inspection and determine the 

UAS is in a condition for safe flight. The pre-flight inspection must account for all 

potential discrepancies, e.g., inoperable components, items, or equipment. 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.

11. The operator must follow the UAS manufacturer’s maintenance, overhaul, 

replacement, inspection, and life limit requirements for the aircraft and 

aircraft components.

12. Each UAS operated under this exemption must comply with all manufacturer 

safety bulletins.

13. Under this grant of exemption, a PIC must hold either an airline transport, 

commercial, private, recreational, or sport pilot certificate. The PIC must also hold a 

current FAA airman medical certificate or a valid U.S. driver’s license issued by a 

state, the District of Columbia, Puerto Rico, a territory, a possession, or the Federal 

government. The PIC must also meet the flight review requirements specified in 

14 CFR § 61.56 in an aircraft in which the PIC is rated on his or her pilot certificate.
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14. The operator may not permit any PIC to operate unless the PIC demonstrates the 

ability to safely operate the UAS in a manner consistent with how the UAS 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 must be logged in a manner consistent with 

14 CFR § 61.51(b). Flights for the purposes of training the operator’s PICs and VOs 

(training, proficiency, and experience-building) and determining the PIC’s ability to 

safely operate the UAS in a manner consistent with how the UAS will be operated 

under this exemption are permitted under the terms of this exemption. However, 

training operations may only be conducted during dedicated training sessions. During 

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

flight operations are considered nonparticipants, and the PIC must operate the UA 

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

15. UAS operations may not be conducted during night, as defined in 14 CFR § 1.1. All 

operations must be conducted under visual meteorological conditions (VMC). Flights 

under special visual flight rules (SVFR) are not authorized.

16. The UA may not operate within 5 nautical miles of an airport reference point (ARP) as 

denoted in the current FAA Airport/Facility Directory (AFD) or for airports not 

denoted with an ARP, the center of the airport symbol as denoted on the current 

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

management is obtained or otherwise permitted by a COA issued to the exemption 

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

to the Administrator or any law enforcement official upon request.

17. 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.

18. If the UAS loses communications or loses its GPS signal, the UA must return to a 

pre-determined location within the private or controlled-access property.

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

20. The PIC is prohibited from beginning a flight unless (considering wind and forecast 

weather conditions) there is enough available power for the UA to conduct the 

intended operation and to operate after that for at least five minutes or with the reserve 

power recommended by the manufacturer if greater.

21. Air Traffic Organization (ATO) Certificate of Waiver or Authorization (COA). All 

operations shall be conducted in accordance with an ATO-issued COA. The 

exemption holder may apply for a new or amended COA if it intends to conduct 

operations that cannot be conducted under the terms of the attached COA.
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22. All aircraft operated in accordance with this exemption must 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 must 

be as large as practicable.

23. Documents used by the operator to ensure the safe operation and flight of the UAS and 

any documents required under 14 CFR §§ 91.9 and 91.203 must be available to the 

PIC at the Ground Control Station of the UAS any time the aircraft is operating. 

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

official upon request.

24. The UA must remain clear and give way to all manned aviation operations and 

activities at all times. 

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

26. All Flight operations must be conducted at least 500 feet from all nonparticipating 

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 in a manner ensuring the safety 

of nonparticipating persons; and

b. The owner/controller of any vessels, vehicles or structures has granted permission 

for operating closer to those objects 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.

The PIC, VO, operator trainees or essential persons are not considered 

nonparticipating persons under this exemption.

27. All operations shall be conducted over private or controlled-access property with 

permission from the property owner/controller or authorized representative. 

Permission from property owner/controller or authorized representative will be 

obtained for each flight to be conducted.

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

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

to the FAA's UAS Integration Office (AFS−80) within 24 hours. Accidents must be 

reported to the National Transportation Safety Board (NTSB) per instructions 

contained on the NTSB Web site: www.ntsb.gov.
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If this exemption permits operations for the purpose of closed-set motion picture and 

television filming and production, the following additional conditions and limitations apply.

29. The operator must have a motion picture and television operations manual (MPTOM) 

as documented in this grant of exemption.

30. At least 3 days before aerial filming, the operator of the UAS affected by this 

exemption must submit a written Plan of Activities to the local Flight Standards 

District Office (FSDO) with jurisdiction over the area of proposed filming. The 3-day 

notification may be waived with the concurrence of the FSDO. The plan of activities 

must include at least the following:

a. Dates and times for all flights;

b. Name and phone number of the operator for the UAS aerial filming conducted 

under this grant of exemption;

c. Name and phone number of the person responsible for the on-scene operation of 

the UAS;

d. Make, model, and serial or N−Number of UAS to be used;

e. Name and certificate number of UAS PICs involved in the aerial filming;

f. A statement that the operator has obtained permission from property owners 

and/or local officials to conduct the filming production event; the list of those 

who gave permission must be made available to the inspector upon request;

g. Signature of exemption holder or representative; and

h. A description of the flight activity, including maps or diagrams of any area, city, 

town, county, and/or state over which filming will be conducted and the altitudes 

essential to accomplish the operation.

31. Flight operations may be conducted closer than 500 feet from participating persons 

consenting to be involved and necessary for the filming production, as specified in the 

exemption holder’s MPTOM.

Unless otherwise specified in this grant of exemption, the UAS, the UAS PIC, and the UAS 

operations must comply with all applicable parts of 14 CFR including, but not limited to, 

parts 45, 47, 61, and 91.
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This exemption terminates on July 31, 2017, unless sooner superseded or rescinded.

Sincerely,

/s/

John S. Duncan

Director, Flight Standards Service

Enclosures
April 24, 2015 

u.s. Department of Transportation 

Docket Management System 

1200 New Jersey Avenue SE 

Washington, DC 20590 

RE: Exemption Request Section 333 of the FAA Reform Act 

Atlanta Marketing Professionals 

Steven Myles Rothacker 

Founder 

678 231-4440 

myles@atlantamarketingprofessionals.com 

Dear Sir or Madam: 

This petition is being submitted on our behalf without legal counsel or consulting services. 

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

Act), and 14 C.F.R. Part 11, Atlanta Marketing Professionals, a full service digital 

marketing and production company, hereby applies for an exemption from the Federal 

Aviation Regulations (FARs) listed below to allow operation of our Small Unmanned 

Aircraft System (sUAS) commercially in airspace regulated by the Federal Aviation 

Administration (FAA) so long as such operations are conducted with and under the 

conditions outlined herein or as may be established by the FAA as required by Section 

333. 

The requested exemption would permit Atlanta Marketing Professionals to pursue its 

commercial interests in providing services to clients using a small advanced sUAV in the 

following areas: 

• Real Estate 

• Marketing 

• Surveying 

• Industrial 

• Special Events 

• Utility Inspection 

• Local and National Natural and Man Made Disaster Rescue 

Atlanta Marketing Professionals states that all sUAS flights will occur over private or 

controlled access property will do so with the property owner's consent and knowledge 

and that only people who have consented or otherwise have agreed to be in the area 

where videography will take place. 
Additionally, Atlanta Marketing Professionals sUAS pilots have over 6 years 

and 400 hours of UAS flight experience. All observers will attend a 40 hour 

training and certification course to insure the safety and observance of all FAA 

Laws, Rules, Guidelines and stipulations. At this training they will trained 

understand the proper roles of an observer, communication procedures, 

proper visual scan techniques, operations at non-towered airports and 

emergency procedures. 

Regulations from which exemption is requested: 

14 C.F.R. Part 21 

14 C.F.R. 45.23(b) 

14 C.F.R. 61.113(a) & (b) 

14 C.F.R. 91.7(a) 

14 C.F.R. 91.9(b) (2) 

14 C.F.R. 91.109 

14 C.F.R. 91.119 

14 C.F.R. 91.121 

14 C.F.R. 91.151 (a) 

14 C.F.R. 91.203(a) & (b) 

14 C.F.R. 91.401 - 91.417(a) & (b) 

XEMPTION REQUESTS AND EQUIVALENT LEVEL OF SAFETY 

. Atlanta Marketing Professionals requests an exemption from the following 

regulations as well as any additional regulations that may technically apply 

to the operation of the sUAV System: 

14 CFR Part 21, Airworthiness Certificates 

This part establishes the procedures for the issuance of an airworthiness 

certificate. While the FAA continues to work to develop airworthiness 

standards for Unmanned Aerial Systems, we request an experimental 

certificate be issued for the OJ I Inspire 1 under either, or both, of the 

following provisions: 

21.191 Experimental certificates. Experimental certificates are issued for 

the following purposes: 

(a) Research and development. Testing new aircraft design concepts, 

new aircraft equipment, new aircraft installations, new aircraft operating 

techniques, or new uses for aircraft. 

(b) Showing compliance with regulations. Conducting flight tests and 

other operations to show compliance with the airworthiness regulations 

including flights to show compliance for issuance of type and supplemental 

type certificates, flights to substantiate major design changes, and flights to 

show compliance with the function and reliability requirements of the 
regulations. Since the experimental certificate can be used for commercial 

purposes such as market surveys, sales demonstrations, and customer 

crew training, we would expect that an experimental certificate would 

permit our commercial purpose as well. The aircraft will not carry persons 

or property, will not carry fuel, and will only fly under strict operational 

requirements. Combined with the UA's light weight, being constructed 

primarily of carbon fiber and plastic, we propose that the UA will be at least 

as safe, if not safer, than a conventionally certificated aircraft performing 

the same mission. If an experimental airworthiness certificate is not 

appropriate for this application, then we request an exemption of 14 CFR 

Part 21, Subpart H, and the requirement for an airworthiness certificate in 

general, citing the equivalent level of safety outlined in the previous 

paragraph. 

14 CFR 45.23 Display of marks; general and 45.29 Size of marks 

The regulation requires: 

When marks include only the Roman capital letter "N" and the registration 

number is displayed on limited, restricted or light-sport category aircraft or 

experimental or provisionally certificated aircraft, the operator must also 

display on that aircraft near each entrance to the cabin, cockpit, or pilot 

. station, in letters not less than 2 inches nor more than 6 inches high, the 

words "limited," "restricted," "light-sport," "experimental," or "provisional," as 

applicable. 

Even though the UAS will have no airworthiness certificate, an exemption 

may be needed as the UAS will have no entrance to the cabin, cockpit or pilot 

station on which the word "Experimental" can be placed. Given the size of the 

UAS, two-inch lettering· will be impossible. The word "Experimental" will be 

placed on the fuselage in compliance with §45.29 (f). 

The equivalent level of safety will be provided by having the UAS marked on 

its fuselage as required by §45.29 (f) where the pilot, observer and others 

working with the UAS wiil see the identification of the UAS as "Experimental." 

14 CFR 61.113 Private pilot privileges and limitations: Pilot in 

Command and 61.133 Commercial pilot privileges and limitations. 

Sections 61.113 (a) & (b) limit private pilots to non-commercial operations. 

Because the UAS will not carry a pilot or passengers, the proposed operations 

can achieve the equivalent level of safety of current operations by requiring the 

PIC operating the aircraft to operate under the supervision of a private pilot's 

license holder rather than a commercial pilot's license holder. Unlike a 

conventional aircraft that carries the pilot and passengers, the sUAS is remotely 

controlled with no living thing on board. The area of operation is controlled and 
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restricted, and all flights are planned and coordinated in advance as set forth in 

the GOM. The level of safety provided by the requirements included in the GOM 

exceed that provided by a single individual holding a commercial pilot's 

certificate operating a conventional aircraft. The risks associated with the 

operation of the sUAS are so diminished from the level of risk associated with 

commercial operations contemplated by Part 61 when drafted, that allowing 

operations of the sUAS as requested with a private pilot in a supervisory role 

aiding the PIC exceeds the present level of safety achieved by 14 C.F.R. 

§61.113 (a) & (b). 

14 CFR 91.7 Prohibits the Operation of an aircraft without an 

airworthiness certificate. 

As no such certificate will be applicable in the form contemplated by the 

FARs, this Regulation is inapplicable. 

14 CFR 91.9 Civil aircraft flight manual, marking, and placard 

requirements. This regulation provides that no person may operate an 

aircraft unless a current, approved flight manual is in the aircraft. We 

assume that the intent of this requirement is to ensure that flight manual 

information is available to the aircrew while operating the aircraft. We 

request an exemption to this requirement since the aircraft is not only too 

, small to carry documentation, the documentation would not be available 

to the crew during flight operations. To obtain an equivalent level of safety 

and meet the intent of 91.9, we propose that a current, approved sUAS 

Flight Manual must be available to the crew at the ground station anytime 

the aircraft is in, or preparing for, flight. 

14 CFR 91.109 Flight Instruction; Simulated instrument flight and 

certain flight tests. 

The regulation states "No person may operate a civil aircraft that is being 

used for flight instruction unless that aircraft has fully functioning dual 

controls." The sUAS System ground-based control station consists of a 

hand-held radio transmitter and while it does not offer a second set of 

"controls", both the student and instructor can, and will, operate the single 

set of controls simultaneously. With both student and instructor having 

"hands-on" the controls during flight, this technique meets the intent 91.109 

and provides an equivalent level of safety. 

91.119 Minimum safe altitudes: General. 

The regulation states that over sparsely populated areas the aircraft cannot 

be operated closer than 500 feet to any person, vessel, vehicle, or 

structure. Since the typical mission of the sUAS would be photography or 

survey of persons, vessels, vehicles or structures it would be necessary to 

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

flown over property or persons where permission has been obtained and 
j. 

!l 

careful pre-planned has been performed. The aircraft will be operated at a 

low altitude allowing, if a power unit fails, an emergency landing without 

undue hazard to persons or property on the surface. Therefore we maintain 

that due to the small size of the UAS, the hazard to persons, vehicles and 

structures is minimal compared to manned aircraft, which should be 

considered in granting the exemption. 

CFR 91.121 Altimeter settings. 

The regulation requires that aircraft shall maintain cruising altitudes by 

reference to an altimeter setting available within 100 NM of the aircraft. 

The sUAS will always fly below 400 feet AGL and will not need to maintain 

cruising altitudes in order to prevent conflict with other aircraft. An Above 

Ground Level altimeter measurement above the takeoff point is 

transmitted via radio from the sUAS on-board computer to the display 

screen held by the PIC, providing a constantly updated AGL readout. 

14 CFR 91.151 Fuel requirements for flight in VFR conditions. 

The regulation provides that no person may begin a flight in an airplane 

under day- vFR conditions unless there is enough fuel to fly to the first 

point of intended landing and to fly after that for at least 30 minutes. We 

. feel the intention of this paragraph is to provide an energy reserve as a 

safety buffer for delays to landing. The sUAV is battery operated and the 

. maximum duration of flight from a single battery charge is 12 minutes with 

a 20% reserve. Since the aircraft will never fly more than 3/4 NM from the 

. point of intended landing, a full battery charge at launch will ensure that we 

meet the reserve energy requirement of this paragraph. We request an 

. exemption to the word "fuel" and ask for an equivalent interpretation with 

the word "energy". 

14 CFR 91.203(a) & (b) Civil aircraft: Certifications required. 

The regulation provides that an airworthiness certificate, with the 

registration number assigned to the aircraft and a registration certificate 

must be aboard the aircraft. Additionally, subparagraph (b) provides that 

the airworthiness certificate be "displayed at the cabin or cockpit entrance 

so that it is legible to passengers or crew." At a maximum gross weight of 

under 6.5 pounds, the sUAS is too small to carry documentation, does not 

have an entrance, and is not capable of carrying passengers or crew. To 

obtain an equivalent level of safety and meet the intent of 91.203, we 

propose that documents deemed appropriate for this aircraft by the FAA 

will be co-located with the crew at the ground control station and available 

for inspection upon request. In order to identify the aircraft, we propose 

that the information found on airworthiness and registration certificates be 

permanently affixed to the aircraft via placard containing the following 

information plus the word "EXPERIMENTAL" to satisfy the requirement of 
14 CFR 45.23. 

14 CFR Subpart E 91.401-91.417- Maintenance, Preventive 

Maintenance, Alterations 

The regulation provides that the operator is primarily responsible for 

maintaining the aircraft in an airworthy condition, including compliance with 

part 39 and 43. 

Paragraphs 91.407 and 91.409 require that the aircraft be "approved for 

return to service by a person authorized under 43. 7" after maintenance and 

inspection. It is our intention that the PIC perform maintenance and 

inspection of the aircraft and "be authorized to approve the aircraft for 

return to service." The PIC will ensure that the aircraft is in an airworthy 

condition prior to every flight and in addition conduct detailed inspections 

after every two hours of flight. Maintenance performed by the PIC is limited 

to repairing small cracks, replacing a propeller, checking electrical 

connections and updating software and firmware for the on-board computer. 

All other maintenance will be performed by the manufacturer or their 

designated repair facility. The PIC will document work performed in 

accordance with 91.417. We feel that due to the size, construction, and 

simplicity of the aircraft, the PIC can ensure an equivalent level of safety. 

All preflight checks will be signed, dated and retained and available at the 

request of the FAA. 

Unmanned Aircraft System 

sUAVs are often seen as superior to helicopters as an aerial video 

gathering platform due to the smaller devices cheaper equipment and 

personnel cost, reduced noise and as such, a much smaller environmental 

impact which promotes public safety. 

Atlanta Marketing Professionals is petitioning for an exemption to operate 

one UAS 

Name: DJI Inspire 1 

Model Number: T600 

Total Weight: 6.5 Lbs. 

Battery Name I Model: Intelligent Flight Battery I TB48 

Battery Capacity: 5700 mAh 

The DJI Inspire 1 features a built-in stabilized HD camera and GPS safety 

features which limit its ability to limit the height it flies above ground level 

(AGL), to limit the radius of the distance it flies from the operator and to 

exclude it from operations within designated Class B, C and D airspace 

including a no-fly zone feature. The DJI The DJI Inspire 1 also has a failsafe 

function that is triggered in the event communication is lost between the 
1; 

sUAS and the main controller transmitter and secondary controller. At that 

time, the sUAS will return to its point of takeoff and land safety. If the 

connection is restored, the PIC can regain control of flight and land 

manually. 

The DJI Inspire 1 Remote Control: 

Name I Model Number: C1 

Operating Frequency: 5.725-5.825 GHz and 2.400-2.483 GHz 

Battery: 6000 mAh LiPo 2S 

The OJ! Inspire 1 owners manual is available on the DJI Website: 

http://download.djiinnovations.com/downloads/inspire_1/en/lnspire_1_User_Manual_v1.0_en.zip 

The specifications of the D J I Inspire 1 meet with the Model Aircraft 

Operating Standards as set below: 

• The petitioner will only operate its sUAS in line-of-sight of a pilot and/or 

observer and will operate at sites that are 'sufficient distance' from 

populated areas within the sterile area described in the FOPM. Such 

operations will ensure that the sUAS will "not create a hazard to users 

of the national airspace system or the public." 

• When flying the sUAS within three (3) miles of an airport, airport 

operators will be notified and the operator will give the right-of-way to 

avoid flying in the proximity of full-scale aircraft 

• Maximum flight time for each operation will be 30 minutes. 

• Flights will be terminated when battery levels reach 25%, allowing 

sufficient reserve flight time to safely land the sUAS. 

• The sUAS will be programmed so it will not be operated at an altitude 

that exceeds 400 feet AGL, and not more than 200 feet above an 

elevated platform from which videography is planned. 

• Minimum crew for each operation shall consist of: sUAS pilot, a 

visual sUAS observer, and the camera operator. 

• The sUAS PIC will be an experience sUAS pilot 

• The sUAS operated by the petitioner weighs less than 25 pounds, 

including all payload (i.e. camera, lens, and stabilized gimbal). 

• The sUAS will operate at speeds of no more than 50 knots, can hover, 

and can simultaneously move vertically and horizontally. 

• Given the small size of the sUAS and the restricted sterile 

environment within which it will operate, Atlanta Marketing 

Professionals' operations adhere to the Reform Act's safety 

requirements. 
The fact the pilots have over 6 years of experience flying sUAS's 

demonstrates Atlanta Marketing Professionals' without incident 

shows a high regard for safe operations with an understanding of FARs, 

pre-flight inspections, knowledge of operations and differences in airspace 

classifications, maintenance and repair, as well as being trained to high 

safety standards. 

By providing this exemption Atlanta Marketing Professionals will serve the 

public interest by providing natural and man made disaster search and 

recovery seNices at the request of local and national emergency responders 

at no fee for as long as required by any such disaster. Furthermore providing 

this exception will allow Atlanta Marketing Professionals to provide utility 

inspection seNices that pose a danger to utility workers. 

Under the requested exemption, Atlanta Marketing Professionals ensures 

all operators have completed sUAS education and training programs 

including all applicable regulations and guidance documents; including 

aeronautical background information such as charts, NOTAMS and 

Aircraft Circulars; Radio Communications Procedures; Human Factors and 

Crew Resource Management; Basic sUAS Aerodynamics; Weather 

factors; Airmanship and Decision-making and Safe Operations 

Procedures. 

We respectively request exemption under Section 333 to enable Atlanta 

Marketing Professionals to operate efficient, limited, low-risk commercial 

sUAS operations for the activities stated respecting at all times the space 

and privacy of citizens and property while keeping airspace safe. 

Sincerely submitted, 

Myles~f3,of acker ,_ 5 ~t 11~ llvt111 f..,.~ 1<-o\lc.c:./c...-

Atlanta Marketing Professionals J 

1420 Cresthaven Lane NW 

Lawrenceville, GA 30043 

678-231-4440