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3/1/16

Anthony Salerno

PO Box 67

Delhi, NY 13753

Office: 607-746-6222

Cell: 607-287-6585

E-mail: mlsa@delhi.net

U.S. Department of Transportation

Docket Management System

1200 New Jersey Ave., SE

Washington, DC 20590

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

2012 

Dear Madam or Sir,

I am writing to request an exemption from the requirements of Title 14 of the Code of

Federal Regulations Sections:

Part 21

45.23

Part 61

91.7(a)

91.9(b)(2)

91.109(a)

91.121

91.151(b)

91.405(a)

91.407(a)(1)

91.409(a)(1) & (a)(2)

91.417(a) & (b)

This exemption request pertains to the commercial operation of the DJI Inspire 1

UAV/UAS pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 

(Public Law 112-95).

INTRODUCTION

By submission of this request, I am seeking exemption from the above regulations, to 

operate and employ the capabilities of this small Unmanned Aerial System to offer 

several commercial aerial photography and videography services for compensation, 

including:
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 Special Marketing Events

 Real Estate Photography & Video

 Property & Land Inspections

 New Construction of Vacant Sports Fields/Facilities

 3D Surface Modeling

 Survey Mapping

 Thermal Imaging

 Aerial Data Collection

 Industrial Facilities Inspections

 Railroad & Bridge Inspections

 Closed Set Motion Picture & Television Filming

 Architectural & Landscape Photography

 Wildlife and Forestry Monitoring

 Search & Rescue Operations (as requested by local Authorities)

 Wedding & Private Individuals’ Special Events

The DJI Inspire 1 is a multi-rotor, vertical takeoff and landing

(VTOL) Unmanned Aircraft (UA) with a Ground Control Station (GCS). There are four 

main rotors driven by Lithium Polymer battery- powered electric motors.

This base DJI Inspire 1 has a maximum gross weight of approximately 2935 grams, 

while having dimensions of 438x451x301 mm, with a maximum speed of approximately 

22m/s. 

The DJI Inspire 1 has a built-in capability to limit the height it flies above

the ground, and to limit the distance (radius) it flies from the operator.

It is further equipped with bolted safety propeller guards. The propeller guards better 

shield the four propellers from contact with other objects, and allow for safer operation.

CFR 14- Part 61- Certification of pilots.....

Specifically, I request an exemption to permit the commercial operation of a

DJI Inspire 1 multi-rotor UAS by myself, an experienced operator with over 600 hours of 

UAV operation time. I possess a current driver's license as well as a private pilot’s 

license (certificate # 110480200) with single and multi- engine ratings and over 165 

flight hours.

Further, Operation would only occur in airspace that is 1) limited, 2) predetermined,

and 3) controlled. If granted, the proposed exemption would allow me to conduct

commercial operations while meeting or exceeding all of the operational and safety

requirements set forth in Section 333.

I also submit 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 
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demonstrated the ability to safely operate it in a manner consistent with the operations 

specifications as described in this exemption, which includes maintaining appropriate 

distances from people, vessels, vehicles and structures.

Further, I submit that all commercial flights of the DJI Inspire 1UAS,

conducted by the PIC pursuant to the grant of this Petition: (1) will be incidental to

my business and (2) will not carry passengers, property or fuel.

14 CFR Part 21, Airworthiness Certificates

This section establishes the procedures for the issuance of an Airworthiness

Certificate. 

The aircraft will not carry persons, property, nor fuel, and will only fly under strict

requirements. Considering the sUAS's light weight and guarded propellers, I believe

that the sUAS will be at least as safe, if not safer, than a conventionally

certificated aircraft performing the same mission.

14 CFR 45.23 Display of Marks; General and 45.29 Size of Marks.

This section establishes requirements for markings on each aircraft.

I have registered my DJI Inspire 1 with the FAA (#FA3WTEF7P3) and will affix said 

registration number, via decal on the external body of same.

14 CFR 91.7 Civil Aircraft Airworthiness

This section prohibits the operation of an aircraft without an Airworthiness

Certificate. As no such certificate will be applicable in the form intended by the FARs,

this regulation is inapplicable.

14 CFR 91.9 Civil Aircraft Flight Manual, Marking, and Placard Requirements.

This section indicates that a current flight manual must be in the aircraft while

operating it. 

Assuming that the intent of this regulation is to have the information

available to the crew if/when needed, I will alternatively have a current UAV flight

manual available at the ground station during preparation and operation.

14 CFR 91.119 Minimum Safe Altitudes: General.

This section indicates that the aircraft cannot be operated closer than 500 feet to

any person, vessel, vehicle, or structure. 

A typical UAV mission would be to achieve detailed videography/photography of 

facilities, and structures. Thus it would be necessary to operate closer than 500 feet to 

the items listed.

My operations will only be flown over property or persons where permission has
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been obtained, and following a pre-planned flight path. They will only be flown within 

visual line of sight (VLOS) and with the assistance of a visual observer (VO)

Furthermore, the UAV will be operated at a low altitude (less than 400 ft. AGL) allowing

for an emergency landing without undue hazard to persons or property on the ground. 

Again, due to the small size and weight of the UAV equipped with propeller guards, the 

hazard to persons, vehicles and structures would be minimal –especially when 

compared to manned aircraft.

CFR 91.121 Altimeter Settings.

This section indicates that aircraft maintain cruising altitudes by reference to an

altimeter setting (within 100 NM of the aircraft).

The UAV will launch in close proximity to our subject, and thus will not need to maintain 

cruising altitudes. An Above Ground Level (AGL) altimeter measurement is transmitted 

via radio from the UAV on-board computer to the ground station's display

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

Additionally- measurements of speed, direction and battery levels are also displayed.

14 CFR 91.151 Fuel Requirements for Flight in VFR Conditions.

This section indicates minimum fuel requirements for aircraft. 

The UAV is battery powered, and will take off and land in close proximity to the 

subject(s) being photographed. My Operating Procedure dictates that operations cease 

once the battery level reaches 30%. The UAV's integrated battery monitor and alarm

system will assure the PIC is aware of battery dropping below 30%. Also, the controller

activates an automatic return to home (RTH) protocol if power drops lower than critical

cut-off setting.

14 CFR 91.203(a) & (b) Civil Aircraft: Certifications Required.

This section indicates that an Airworthiness Certificate must be aboard the

aircraft.

The UAV is too small to carry documentation, does not have an entrance, and

is incapable of carrying passengers or crew. The documents deemed appropriate for

this aircraft by the FAA will be available at the ground control station. Aircraft

identification is addressed above in 14 CFR 45.23.

14 CFR 91.205(a), (b) Instrument and Equipment Requirements

This section defines a set of instruments and equipment required for day VFR

flight.

Airspeed, AGL and compass indicators are provided on the Ground Station

Controller display. 
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The Ground Station Controller flight screen also provides the following information:

1. Aircraft's height in feet (AGL).

2. Aircraft's distance from Ground Station Controller in feet.

3. Aircraft's vertical speed in mph.

4. Aircraft's horizontal speed in mph.

5. Aircraft's front camera view.

6. Map position.

7. Firmware status (all devices).

8. Aircraft's indicator light status.

9. Compass status (Calibration needed or normal).

10. Gimbal status.

11. Radio controller signal quality.

12. Flight mode (P, A or F)

13. Intelligent flight battery level (%).

14. Intelligent flight battery temperature (centigrade)

15. Controller battery level (%).

16. SD card capacity.

17. Camera controls (not relative to flight control).

The telemetry information provided by the controller in conjunction with

continuous visual flight monitoring is believed to provide sufficient aircraft operating

indicators.

14 CFR Subpart E (91.401- 91.417)- Maintenance, Preventive Maintenance,

Alterations

This section involves maintaining the aircraft in an airworthy condition.

As PIC, I will perform normal maintenance of the aircraft prior to every flight including a 

detailed inspection. I will approve the aircraft for return to manufacturer for service if 

deemed necessary. Any maintenance performed by the PIC is limited to replacing 

propellers, 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. Due to the size and simplicity of this aircraft, the PIC can ensure an

equivalent level of safety.

SAFETY AND BENEFITS OF THE UAV

I will be using the UAV in a variety of applications that previously required use of fullsize, manned aircraft to complete. These previously traditional methods of acquiring

aerial photography are simply not viable options for the average consumer as they are 

costly and pose greater risks to everyone. 
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UAVs offer many benefits over the use of full-sized manned aircraft. Replacing 

significantly larger manned aircraft carrying crew and flammable fuel with small UAVs

carrying no passengers or crew creates a much greater margin of safety. 

By granting my requested exemptions, the FAA will help drive development of safe and 

successful commercial UAV operations; will advance the public knowledge base for 

such operations.and allow me to provide data; information and images that were

previously not available to the average consumer.

CONCLUSION

As discussed in this petition, the UAV which I would utilize, under FAA

authorization, is a light-weight device operated within the line of sight of the PIC, less 

than 400 feet above the ground and outside a 5-mile radius from any airport,

heliport, or other location with aviation activities, unless the air traffic control authorities 

(ATC) have been notified and have authorized each flight within a radius of this 

distance.

The DJI Inspire 1 UAV has proven capability for controlled flight. They are devices

offered for general sale on the market around the world. We are certain that the studies 

conducted until now by the FAA, ( Section 332, Public Law 112-95, 2014), have already 

provided you with confidence in the airworthiness of a UAV such as mine.

For the foregoing reasons, I’m hoping the exemptions requested herein should be 

granted and I will be permitted to conduct UAV operations in accordance with all

operating parameters deemed necessary and appropriate by the FAA.

Additionally, if granted, I would like to exercise the privileges of these exemptions 

outside the US, given my proximity to the Canadian border and since I have numerous 

Canadian business contacts that may request my services.

The granting of this exemption and its contents is the best demonstration that some 

UAVs may be used for legitimate commercial activities and under reasonably safe 

conditions.

Please note that the requests of this petition are similar to those of Mr. Sande Kornblum 

(“Skies the Limit Printing, Inc.) and Mr. Jeffery R. Kochanowski (JEKO Video)- all of 

whom have received Section 333 exemptions for comparable aircraft and similar 

business operations.

If any individual aspect of this request for exemption is unacceptable, I request

that it be struck alone and the remainder of the exemption be allowed as requested.

Respectfully Submitted,

Anthony Salerno
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Attachments:

DJI Inspire 1 Documents (2)

NYS Driver’s License

Pilot certificate