UNITED STATES OF AMERICA

DEPARTMENT OF TRANSPORTATION

FEDERAL AVIATION ADMINISTRATION

WASHINGTON, D.C.

Regulatory Docket No. _______________

IN THE MATTER OF THE PETITION FOR EXEMPTION OF:

TIM GIBBONS VIDEOGRAPHY, INC.

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 THE

DJI INSPIRE 1 UNMANNED AIRCRAFT SYSTEM

PURSUANT TO SECTION 333 OF

THE FAA MODERNIZATION AND REFORM ACT OF 2012 (PUBLIC LAW 112-95)

Submitted on June 9, 2015

Tim Gibbons Videography, Inc.

1419 E. Harvard Ave.

Salt Lake City, Utah 84105

Tel: (801) 557-5226
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TABLE OF CONTENTS

GLOSSARY OF ABBREVIATIONS.........................................................................3

SUMMARY..............................................................................................................4

INTRODUCTION AND INTERESTS OF PETITIONER...........................................4

BACKGROUND.......................................................................................................4

BASIS FOR PETITION............................................................................................5

NAME AND ADDRESS OF PETITIONER....................................................6

THE SPECIFIC SECTIONS OF 14 C.F.R. FROM WHICH

GIBBONS VIDEORAPHY SEEKS EXEMPTION..........................................6

THE EXTENT OF RELIEF GIBBONS VIDEOGRAPHY SEEKS AND

THE REASON GIBBONS VIDEOGRAPHY SEEKS THE RELIEF..............10

THE REASONS WHY GRANTING GIBBONS VIDEOGRAPHY

REQUEST WOULD BE IN THE PUBLIC INTEREST ................................12

THE REASONS WHY GRANTING THE EXEMPTION

WOULD NOT ADVERSELY AFFECT SAFETY...........................................14

SUMMARY THAT CAN BE PUBLISHED IN THE

FEDERAL REGISTER..................................................................................25

ANY ADDITIONAL INFORMATION, VIEWS, OR

ARGUMENTS AVAILABLE TO SUPPORT GIBBONS

VIDEOGRAPHY’S REQUEST......................................................................25

REQUEST FOR BLANKET COA APPROVAL..............................................26

CONCLUSION..........................................................................................................27

APPENDIX A - DJI INSPIRE 1 TECHNICAL SPECIFICATIONS.........................28

APPENDIX B - DJI INSPIRE 1 MANUFACTURER’S USER MANUAL.................30

APPENDIX C - MONTHLY MAINTENANCE LOG...........................................31
3

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

Tim Gibbons Videography Inc. 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 Tim Gibbons 

Videography Inc. to operate an Unmanned Aircraft System (UAS) for the commercial purpose of 

conducting aerial video and photography for broadcast production, motion picture filming, non 

profit promotional videos multi-media presentations and internet based video production over 

certain areas of the United States.

INTRODUCTION AND INTERESTS OF THE PETITIONER

Tim Gibbons Videography Inc. (hereinafter referred to as “Gibbons Videography”) provides 

it’s clients with expertise and knowledge in advanced technologies and solutions to increase 

efficiency, productivity and effectiveness. Gibbons Videography provides clients with the highest 

quality digital content for use in broadcast, commercial, personal, and non-profit projects. Gibbons 

Videography has been in business for over 20 years and has professional experience in television 

broadcast, industrial and nonprofit video production and is recognized as an expert this field. 

Gibbons Videography has recreational/hobby experience in all aspects of aerial videography. The 

objective of Gibbons Videography aerial video operations is to provide high quality imaging for a 

variety of broadcast, commercial and nonprofit productions, specifically targeting:

• Broadcast Television Production

• Motion Picture Filming

• Non Profit Promotional Videos

• Multi-media Presentations

• Internet Based Video Production

• Increase public knowledge of UAS and promote safe UAS operations.

BACKGROUND

Unmanned Aircraft System: DJI Inspire 1 UAS

Gibbons Videography seeks an exemption to operate DJI systems for compensation or 

hire within the NAS. The DJI Inspire 1 is a vertical takeoff and landing (VTOL) Unmanned Aircraft 

(UA) with a Ground Control Station (GCS) utilizing 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.

The DJI Inspire 1 UA that will be operated by Gibbons Videography 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.
5

BASIS FOR PETITION

Petitioner, Gibbons Videography 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, Gibbons Videography’s operation of the 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, Gibbons Videography 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.

Gibbons Videography submits that the requested relief is proper since an equivalent level 

of safety will be ensured. Gibbons Videography will use experienced personnel or technicians to 

perform maintenance, alterations, or preventive maintenance on the UASs using the methods,

techniques, and practices prescribed in the operating documents (i.e., Monthly Maintenance Log, 

and DJI Inspire 1 Instruction Manual). Furthermore, Gibbons Videography 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 Gibbons Videography 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 flighthour 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.

Gibbons Videography seeks relief from Section 91.7(a), entitled Civil aircraft airworthiness,

because the Inspire 1 UAS does not require an airworthiness certificate in accordance with 14

C.F.R. Part 21, Subpart H. As such, Gibbons Videography submits that he will ensure that the DJI

Inspire 1 UAS is in an airworthy condition, prior to every flight, by determining that the UAS is in 

compliance with the operating documents (i.e., Monthly Maintenance Log, and DJI Inspire 1 

Instruction Manual), and that the aircraft is in a condition for safe flight.

Gibbons Videography also seeks an exemption from the requirements of Section 91.121, 

entitled Altimeter Settings, as DJI Inspire 1 UA does not have a typical barometric altimeter 

onboard. However, altitude information of the DJI Inspire 1UAs 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, 

combined with Gibbons Videography 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, Gibbons Videography seeks an exemption from the requirements of Section
6

91.151(b), entitled Fuel requirements for flight in VFR conditions. Gibbons Videography 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, Gibbons Videography 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:

Tim Gibbons Videography Inc.

1419 E. Harvard Ave.

Salt Lake City, Utah 84105

Tel: (801) 557-5226

tim@timgibbons.com

B. The Specific Sections Of 14 C.F.R. from Which Gibbons Videography Seeks Exemption.

1. Gibbons Videography 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. Gibbons Videography 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.
7

3. Gibbons Videography 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. Gibbons Videography 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. Gibbons Videography 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[.]
8

6. Gibbons Videography 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. Gibbons Videography Seeks Exemption From The Requirements Of Sections 

91.409(a)(1) And 91.409(a)(2).

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. Gibbons Videography 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--
9

(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:

(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
10

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 Gibbons Videography Seeks And The Reason Gibbons 

Videography Seeks That Relief.

1. Extent Of Relief Gibbons Videography Seeks And The Reason Gibbons 

Videography 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, Gibbons Videography 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 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, Gibbons Videography 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 Gibbons Videography

business; and (2) will not carry passengers or property for compensation or hire.

2. Extent Of Relief Gibbons Videography Seeks And The Reason Gibbons 

Videography 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 Gibbons Videography to determine that the DJI Inspire 1 UAS is in 

airworthy condition prior to every flight by ensuring that the UAS is in compliance with the 

operating documents (i.e., the Gibbons Videography Aerial Operations Manual, Monthly 

Maintenance Log, and DJI Inspire 1 Instruction Manual).

Gibbons Videography 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, 
11

Gibbons Videography 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 Gibbons Videography Seeks And The Reason Gibbons 

Videography 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 utilizes 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),

Gibbons Videography 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 is 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 Gibbons Videography Seeks And The Reason Gibbons 

Videography 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. Gibbons Videography

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 Gibbons Videography proposes to conduct

pursuant to this Petition.

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

documents, and Gibbons Videography proposed operating limitations, ensure that Gibbons 

Videography 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.
12

5. Extent Of Relief Gibbons Videography Seeks And The Reason Gibbons 

Videography 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, Gibbons Videography 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 meets the conditions of FMRA Section 333 for

operation without an airworthiness certificate. Accordingly, Gibbons Videography 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.,

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

Videography will document and maintain all maintenance records for the DJI Inspire 1 UAS.

D. The Reasons Why Granting Gibbons Videography 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 Gibbons 

Videography to safely, efficiently, and economically perform aerial video and photography for TV 

broadcast, industrial, non profit, multi-media, special events, documentary and feature film 

production over certain areas of the United States.

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

pollution, and provide significant benefits to the economy. Notably, the benefits of Gibbons 

Videography’s 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 is battery powered and serves 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 the 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.

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.
13

2. The Public Will Benefit From The Safety And Efficiency Of The DJI Inspire 1 UASs.

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 produces 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 is propelled by battery

powered electric motors, rather than an internal combustion engine.

By using the DJI Inspire 1 UASs 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 it’s maximum gross weights with a 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. 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 is also an economical 

alternative to using manned aircraft to conduct similar aerial operations. As such, operation of the 

DJI Inspire 1 UAS will allow United States based companies, like Gibbons Videography, 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 Gibbons Videography, 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.
14

4. There Are No Privacy Issues.

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

decades, Gibbons Videography 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 Gibbons Videography 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 Gibbons Videography Seeks Exemption.

1. Reasons Why 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, Gibbons Videography operation of the DJI Inspire 1 

UAS meets 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

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
15

(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, Gibbons Videography 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 UASs Demonstrate Its Safe 

Characteristics.

The DJI Inspire 1 UASs do 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 UASs.

The technical specifications of the DJI Inspire 1 UAS are set forth by the DJI Inspire 1

Specifications and Data Sheet, attached hereto as Appendix A.

ii. The DJI Inspire 1 UAS Autonomous Flight And Navigation Modes 

Enable The UASs 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 Manual, attached hereto as Appendix B.

iii. The DJI Inspire 1 UAS Is 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 UA 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
16

shutdown.

A complete description of the Failsafe Functions of the DJI Inspire 1 at pages 13 through 

15 of 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 48 of the DJI Inspire 1 User

Manual. DJI Inspire 1 User Manuals is attached here to as Appendix B.

b. Flight Operations Of DJI Inspire 1 UAS Are Limited To The Line Of Sight Of 

A Certificated Pilot in Command With A Safety Observer.

Gibbons Videography will only utilize certificated pilots who possess a current and valid 

airman medical certificate 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, Gibbons Videography 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 UASs 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.

3. The UAs may not be flown at an indicated airspeed exceeding 44 knots.

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

(AGL), as indicated by the procedures specified in the operating documents unless a 

special request is made and approved by ATC. 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.
17

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.

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.
18

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 thirdclass 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 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 
19

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 

predetermined 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 (NNumber) markings in accordance 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.
20

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 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.

Gibbons Videography 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 Gibbons Videography’s proposed area of operations, and the operating 

limitations set forth-above; the parallel nature of private pilot aeronautical knowledge 
21

requirements to those of commercial pilot requirements (See Exemption No. 11062); and the 

airmanship skills necessary to safely operate the DJI Inspire 1 UAS, Gibbons Videography

submits that the additional manned airmanship experience of a commercially certificated pilot 

would not correlate to the airmanship skills necessary for Gibbons Videography 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).

Gibbons Videography 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 Gibbons Videography’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), 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
22

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, Gibbons Videography 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, Gibbons Videography 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 downlinks from the UA to the GCS for active 

monitoring of the flight path and altitude. This altitude information, combined with Gibbons 

Videography 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’s 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).
23

5. Reasons Why An Exemption From The Requirements Of Section 91.151(b) Would 

Not Adversely Affect Safety.

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, Gibbons Videography 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 provides audible and visual warnings to the PIC 

at the GCS when the UA experiences low battery voltage, the first warning occurring at 

approximately 30% 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.

In seeking this exemption, Gibbons Videography 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

Gibbons Videography will use trained technicians to perform maintenance, alterations, or 

preventive maintenance on the UASs using the methods, techniques, and practices prescribed in 

the operating documents (i.e., the Gibbons Videography’s Aerial Operations Manual, Monthly 

Maintenance Log, and DJI Inspire 1 Instruction Manual). Furthermore, Gibbons Videography 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, 

Gibbons Videography 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 DJI Inspire 1 User Manuals are attached 
24

hereto as Appendix B; a copy of the DJI Inspire 1 UAS Maintenance LOG is attached hereto as 

Appendix C.

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

Videography 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 Gibbons Videography proposed operating limitations, the operating

documents, and the technical aspects of the DJI Inspire 1 UAS, Gibbons Videography 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, Gibbons Videography 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), 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
25

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 Gibbons Videography’s 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 Gibbons Videography Seeks Exemption:

Gibbons Videography 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 Gibbons Videography Seeks:

This exemption will permit Gibbons Videography to commercially operate an Unmanned 

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

certain areas of the United States.

G. Any Additional Information, Views, Or Arguments Available To Support Gibbons 

Videography’s Request:

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, Gibbons Videography’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.
26

As discussed in detail above, Gibbons Videography will operate the DJI Inspire 1 UASs 

safely in the NAS, without creating a hazard to users of the NAS, or the public, or otherwise pose 

a threat to national security.

H. Request for Blanket COA Approval

On March 24, 2015, the FAA announced that it has implemented a new policy of granting 

"blanket" COAs to applicants requesting exemptions from the Federal Aviation Regulations under 

Section 333 of the FAA Modernization and Reform Act of 2012. The Applicant hereby requests 

that a "blanket" COA that conforms to the terms set forth in 

https://www.faa.gov/news/updates/?newsId=82245 upon approval of Gibbons Videography’s

exemption request.
27

CONCLUSION

As set forth herein, Gibbons Videography 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 Gibbons Videography 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, Gibbons Videography 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 Gibbons Videography to operate the DJI Inspire 1 UAS 

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

the United States.

Finally, I would like to personally thank the FAA and all it’s employees for working towards 

integrating UASs into the NAS. I have no doubt that the process is incredibly challenging. 

Juggling the needs of various industries and maintaining the safety of our national airspace must 

be extremely daunting. As a filmmaker, I sincerely appreciate the administration’s efforts to 

address the needs of our industry and work towards finding a way to safely integrate this 

incredible technology into our storytelling.

Dated: June 9, 2015

Respectfully submitted,

Tim Gibbons Videography, Inc.

Timothy Gibbons, Owner

1419 E. Harvard Ave.

Salt Lake City, Utah 84105

Tel: (801) 557-5226
28

APPENDIX – A

DJI INSPIRE 1 TECHNICAL SPECIFICATIONS

Gibbons Videography only utilizes safe and reliable UASs. DJI is an industry leader in small UAS

production. DJI UASs are loaded with ground breaking software enabling the user to set

parameters which will not allow flight into controlled airspace. Parameters can also be set to limit 

flight to no higher than a predetermined and set altitude as well as limit flight to a predetermined 

and set distance. In addition, DJI software provides real-time altitude and location information to 

the PIC via the linked monitor (smart phone/tablet devices)

1.1 DJI Inspire

1.1.1 Aircraft

1.1.1.1 Model – T600

1.1.1.2 Weight (Battery Included) – 6lbs 7.5291oz (2935g)

1.1.1.3 Hovering Accuracy (GPS Mode) – Vertical: 0.5m; Horizontal: 2.5m

1.1.1.4 Max Angular Velocity – Pitch: 3000/s; Yaw: 1500/s

1.1.1.5 Max Tilt Angle ‐ 350 3.2.1.6 Max Ascent Speed – 5m/s

1.1.1.6 Max Ascent Speed – 5m/s

1.1.1.7 Max Descent Speed – 4m/s

1.1.1.8 Max Speed – 22m/s (ATTI mode, no wind – NOT RECOMMENDED)

1.1.1.9 Max Flight Altitude – 4500m

1.1.1.10 Max Wind Resistance – 10m/s

1.1.1.11 Max Flight Time – Approximately 18 minutes

1.1.1.12 Motor Model – DJI 3510

1.1.1.13 Propeller Model – DJI 1345

1.1.1.14 Operating Temperature Range – 140F to 1040F (‐100C to 400C)

1.1.1.15 Dimensions – 17 1/4” x 17 3/4” x 12”

1.1.2 Gimbal

1.1.2.1 Model – ZENMUSE X3

1.1.2.2 Output Power (with camera) – Static: 9W; In Motion: 11W

1.1.2.3 Operating Current – Static: 750mA; In Motion: 900mA

1.1.2.4 Angular Vibration Range ‐ Å}0.030

1.1.2.5 Mounting – Detachable

1.1.2.6 Controllable Range – Pitch: ‐900 to +300; Pan: Å}3200

1.1.2.7 Mechanical Range – Pitch: ‐1250 to 450; Pan: Å}3300

1.1.2.8 Max Controllable Speed – Pitch: 1200/s; Pan: 1800/s
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1.1.3 Camera

1.1.3.1 Name – X3

1.1.3.2 Model – FC350

1.1.3.3 Total Pixels – 12.76M

1.1.3.4 Effective Pixels – 12.4M

1.1.3.5 Image Max Size – 4000x3000

1.1.3.6 ISO Range – 100--‐3200

1.1.3.7 Field of View ‐ 940

1.1.3.8 CMOS – Sony EXMOR 1/2.3”

1.1.3.9 HD Video Recording – UHD(4K): 4096x2160p24/25,

3840x2160p24/25/30; FHD:1920x1080p24/25/30/48/50/60;

HD: 1280x720p24/25/30/48/50/60

1.1.3.10 Operating Temperature Range: 320F ‐ 1040F (00C - 400C)

1.1.4 Transmitter

1.1.4.1 Name – C1

1.1.4.2 Operating Frequency: 5.728--‐5.850GHz; 2.400--‐2.483GHz

1.1.4.3 Communicating Distance (unobstructed): 2000m

1.1.4.4 Output Power: 9W

1.1.4.5 Operating Temperature Range: 140F to 1040F (‐100C to 400C)

1.1.4.6 Battery: 600mAh LiPo 2S 32
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APPENDIX – B

DJI INSPIRE 1 MANUFACTURER’S USER MANUAL

Most current version of the user manual can be found at:

http://www.dji.com/product/inspire-1/download
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APPENDIX – C

Gibbons Videography Monthly Maintenance Log