KeyConcepts, LLC d/b/a Key-AerialGraphics 

3229 East Friess Drive 

Phoenix AZ 85032 

PH: (602) 456-5404

FAX: (866) 771-7636

March 23, 2015 

United States Department of Transportation

Docket Management System

1200 New Jersey Ave., SE

West Building Ground Floor Room W12-140

Washington, DC 20590

Re: Exemption Request under Section 333 of the FAA Reform Act and Part 11 of the Federal 

Aviation Regulations 

Dear Sir or Madam: 

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

14 C.F.R. Part 11, KeyConcepts, LLC d/b/a Key-AerialGraphics (KAG) seeks an exemption from 

Federal Aviation Regulations (“FARs”) detailed below for the following described Unmanned Aerial 

System called in this application the KAG System, which includes an Unmanned Aircraft and ground 

station-based equipment and crew: 

Request

I am writing pursuant to the FAA Modernization and Reform Act of 20121 (the "Reform

Act") and the procedures contained in 14 C.F.R. 11, to request that KeyConcepts, LLC, d/b/a/ as 

Key-AerialGraphics, an owner and operator of a DJI Inspire 1 sUAS be exempted from the Federal 

Aviation Regulations ("FARs") listed below so that KeyConcepts, may operate its Inspire 1 ("sUAS") 

commercially in airspace regulated by the Federal Aviation Administration ("FAA"); as long as such 

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

the FAA as required by Section 333. The conditions identified and proposed by the applicant are:

To operate the DJI Inspire 1 within the proposed regulations as listed in the recently published 

“Small sUAS Notice of Proposed Rule-making (NPRM) to add Part 107, released February 23, 

2015. Authorization for this request is to use the sUAS to support aerial photography and video 

primarily of real property.

Additionally as business expands and skill sets adhere to the required skills for the task; 

KeyConcepts request authorization to support aerial cinematography on both closed and open sets; 

assist in survey work for structures, pipelines and agriculture and be able to assist in any search and 

rescue missions if requested by local law enforcement or emergency services. Our primary interest 

as this time is real estate property and I am prepared to resubmit for the additional requested 

authorizations at a later date and request these additional request not prevent the approval of our 

primary request of real estate photography and videography. 
These request will help in the local real estate market and provide a valuable service that will both 

improve safety from utilizing manned aircraft to get low level (low altitude) small operating area 

restrictions required by manned aircraft to achieve such photos of real estate property. Additionally 

there is a price reduction in this service, opening the market up to a larger customer base and 

increasing opportunities for the entire real estate market. Because the sUAS is better suited for this 

type of operation and indeed the Inspire 1 operated by KeyConcepts was specifically designed by DJI 

(but not limited to) with this market in mind. 

sUAS Operator

The sUAS Operator Robyn Willow Key, owner of KeyConcepts is a licensed Private Pilot, Airplane 

Single Engine Land with Rotorcraft-Helicopter and Instrument Helicopter. Holding a third class 

medical. Concerning the (pilot) operator of the sUAS, in addition to the pilot ratings and 

understanding of the National Airspace System (NAS), is currently taking flight instruction for sUAS 

systems at RotorFX in Van Nuys, CA. RotorFX trains pilots Airplane and Rotorcraft in addition to 

their sUAS training program. This provides them good knowledge of the Federal Aviation 

Regulations (FAR) and how sUAS fit into the NAS safely. This was a considering factor when 

choosing a sUAS operations training program. The (pilot) operator also maintains a logbook of all 

flights involving sUAS as well as general RC Aircraft as many of the same skills are utilized.

sUAS

The sUAS is a DJI Inspire 1, 4 motor/rotor, system weighing 2935 g with battery and camera system. 

A factory designed and installed gimbal and camera system, which are built into the sUAS as a 

complete system from the factory. The top speed of the Inspire 1 is 22 m/s (ATTI mode, no wind) 

The Inspire 1 is designed to be operated utilizing a single controller or by utilizing a duel controller 

system, where the (pilot) operator controls the sUAS with a Master transmitter and the (camera) 

operator controls the gimbal camera and recording functions. KeyConcepts intends to use the duel 

controller setup allowing the (pilot) operator to concentrate on flying the sUAS Visual Line of Site 

(VLOS) and the (camera) operator to concentrate on the video and/or photos. Included in this 

application is the Inspire 1 User Manual, Inspire 1 Safety Guidelines and the Inspire 1 Intelligent 

Flight Battery Safety Guidelines. In addition to the (pilot) operator for KeyConcepts maintaining 

flight log books; KeyConcepts is maintaining flight logs on all it’s UAS (currently the Inspire 1) 

utilized in their operations. Tracking flight times, battery use and performance; as well as 

maintenance on the sUAS. The guidelines for maintenance adhere to the DJI Inspire 1 safety 

guidelines enclosed. Additionally KeyConcepts proposes to adhere to the Operation Limitations 

proposed in the NPRM and set forth in the pending exemption request. Considering limitations 

between the NPRM and exemption requested henceforth and the Inspire 1 Safety guidelines and 

where there are any differences, KeyConcepts proposes to follow the imitations affording the best 

margin of safety in operations. 
General Guidelines

The UAS will only be operated VLOS and with a Visual Observer (VO) in accordance with FAA 

Policy N 8900.227 Section 14 "Operational Requirements for sUAS" and with the following 

Restrictions: 

(a) No flight will be made with a sUAS Gross weight exceeding the standard factory configuration 

of 2935 g 

(b) All operations must occur in FAA Class G airspace at no more than 400 ft AGL, at an airspeed of 

no more than 22 m/s and within VLOS of PIC; 

(c) All operations must utilize a visual observer (VO). The VO and PIC must be able to communicate 

by voice at all times during a flight operation; 

(d) Operations will be restricted to flights over private property with the permission of the property 

owner; 

(e) The PIC must have accumulated and logged, in a manner consistent with 14 CFR § 61.51 (b), a 

minimum of 100 flight cycles and 25 hours of total time as a UA rotorcraft pilot and at least ten hours 

logged as a UA pilot with a similar UA type; 

(f) All required permits will be obtained from state and local government prior to operation; 

(g) The UAS will not be operated over densely populated areas; 

(h) The UAS will not be operated over any open-air assembly of people; 

(i) The UAS will not be operated over heavily trafficked roads; 

(j) The UAS will not be operated within 5 NM of an airport or heliport unless ATC has been notified 

of said operation and confirms there will be no conflict with air traffic, additional to obtaining prior 

approval from ATC to operate within the 5NM area, aircraft communications will be monitor with a 

hand held aircraft transceiver; ATC will be notified of flight start and stop times. 

(k) Operations will be restricted to day only and weather conditions equivalent to VFR; 

(l) The PIC will brief the VO and property owner about the operation and risk before the first flight at 

each new location; 

(m) No flight may be made without a Pre-Flight Inspection by the PIC before each operation to 

ascertain that the sUAS is in a condition safe for flight (see Inspire 1 Safety Guidelines). 

The PIC and VO will meet the requirements outlined in FAA Policy N 8900.227 Section 16 

personnel Qualifications. 

I submit that the combination of the sUAS's light weight, flight performance and ability, fully 

qualified flight crew and strict operation under the guidelines established in 8900.227, and under all 

of the Restrictions (a) through (m) listed above, the FAA can have full confidence that the operation 

will have an equivalent or greater level of safety than manned aircraft performing the same mission. 

The name and contact information of the applicant is: 

KeyConcepts, LLC d/b/a Key-AerialGraphics 

Attn: Robyn Willow Key 

PH: (602) 456-5404

FAX: (866) 771-7636

Email: Robyn@Key-AerialGraphics.com
KeyConcepts respectfully requests the grant of an exemption allowing it to

operate lightweight, remote controlled sUAS’s. (Currently it’s Inspire 1)

Specifically KeyConcepts Requests Exemption from the following:

- 14 CFR Part 21.................................Addendum Page 1 

- 14 CFR 91.203.................................Addendum Page 1 

- 14 CFR 45.23, 45.29..........................Addendum Page 2 

- 14 CFR 91.9....................................Addendum Page 2 

- 14 CFR 61.113, 61.133.......................Addendum Page 2 

- 14 CFR 91.109, 91.119, 91.121..............Addendum Page 3 

- 14 CFR 91.151.................................Addendum Page 4 

- 14 CFR Subpart E (91.401 - 91.417) ......Addendum Page 4 

- FAA Policy 8900.227 Paragraph 16(c)(4) and Paragraph 16(e)(1) ...Addendum Page 4 

I am prepared to modify or amend any part of this request to satisfy the need for an equivalent level 

of safety. Please contact me at any time if you require additional information or clarification. I look 

forward to working with your office. 

Sincerely, 

Robyn Willow Key 

Key-AerialGraphics 

Private Pilot Certificate No. 3276918

Addendum containing Exemption Requests and Equivalent Level of Safety 

Additionally submitted documentation in support of this request include: 

Inspire 1 User Manual 

Inspire 1 Safety Guidelines 

Inspire 1 Intelligent Flight Battery Safety Guidelines 
ADDENDUM

EXEMPTION REQUESTS AND EQUIVALENT LEVEL OF SAFETY 

KeyConcepts, LLC, requests an exemption from the following regulations as well as any 

additional regulations that may technically apply to the operation of the Inspire 1 sUAS: 

14 CFR Part 21, Subpart H: 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, I 

request an experimental certificate be issued for the 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) (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, I 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 sUAS’s light weight, being constructed primarily 

of carbon fiber and plastic, I propose that the sUAS 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 I 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 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 2935 grams, the Inspire 1 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, I 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, I 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 

Addendum Page 2 of 4 satisfy the requirement of 14 CFR 45.23, which follows immediately 

after the proposed placard description below: 

EXPERIMENTAL 

Manufacturer: DJI Innovations, Inc. 

3229 E Friess Dr

Phoenix AZ 85032

Model: T600, Serial Number: W13DCA0820744

If found please contact: (602) 456-5404

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

These regulations provide that each aircraft must display "N" and the aircraft's registration 

number in letters at least 3 inches high. Additionally, the aircraft must display the word 

"EXPERIMENTAL" in letters at least 2 inches high near the entrance to the cabin, cockpit, or 

pilot station. The sUAS does not have an entrance in which the word "EXPERIMENTAL" can be 

placed, and may not have a registration number assigned to it by the FAA. 

I propose to achieve an equivalent level of safety by including the word "EXPERIMENTAL" 

in the placard on the top of the aircraft, as shown above, where the PIC, VO and others in the 

vicinity of the aircraft while it is preparing for launch will be able to see the designation. 

Additionally, I feel that the permanent placard discussed in the previous paragraph will provide 

the aircraft's registration information at the ground station. Finally, I will display at the ground 

station a high contrast flag or banner that contains the words "Unmanned Aircraft Ground 

Station" in letters 3 inches high or greater. Since the aircraft will operate within 1.5 KM of the 

ground station, the banner should be visible to anyone that observes the aircraft and chooses to 

investigate its point of origin.

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. I assume that the intent of this requirement is to ensure that flight 

manual information is available to the aircrew while operating the aircraft. I 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, I propose that a current, 

approved sUAS Flight Manual (Appendix A) must be available to the crew at the ground station 

anytime the aircraft is in, or preparing for, flight. 
14 CFR 61.113 Private pilot privileges and limitations: Pilot in Command and 61.133 

Commercial pilot privileges and limitations. 

The regulation provides that no person that holds a private pilot certificate may act as pilot in 

command of an aircraft for compensation or hire. Subparagraph (b) allows a private pilot to act 

as pilot in command 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. 

My proposed operations require that the PIC must either

 1. Hold a Commercial Pilot Certificate issued by the FAA, and have logged 25 hours of 

flight experience in this type of UA, or 

 2. Meet the requirements of 8900.227 para 16(c)(2)(c) "Operations without a pilot 

certificate" in which the PIC is required to complete "FAA private pilot ground instruction" and 

pass "the FAA Private Pilot written examination." Since there are currently no means available 

for the pilot of a UAS to gain the experience in an equivalent category and class in order to apply 

for a commercial pilot's license, I propose to generate an equivalent level of safety by submitting 

that I currently hold a private pilots certificate in both airplanes and rotorcraft. Since the aircraft 

cannot carry passengers or property, I feel I meet the intent of 61.113 Subparagraph (b) even 

though the intent of this application is to conduct a business. 

14 CFR 91.109 Flight Instruction; Simulated instrument flight and certain flight tests

The regulation states that "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 small hand-held radio transmitter 

and while it does not offer a second set of “controls for flight", 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, I feel that this technique meets the intent 91.109 

and provides an equivalent level of safety.

14 CFR 91.119 Minimum safe altitudes. 

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 aircraft will be operating at a 

maximum of 400 feet AGL, I cannot comply with this requirement. 

In order to provide an equivalent level of safety I will only fly over private property with the 

permission of the owner of the property flown over. The aircraft will not be operated over 

congested areas or over any open air assembly of persons. The property owner will be briefed on 

the expected route of flight and the associated risks to persons and property on the ground. 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 I maintain that due to the 

small size of the sUAS, the hazard to persons, vehicles and structures is minimal compared to 

manned aircraft, which should be considered in granting the exemption.
14 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. 

I feel the intention of this paragraph is to provide an energy reserve as a safety buffer for 

delays to landing. The sUAS is battery operated and the maximum duration of flight from a 

single battery charge is 17.5 minutes with a 23% reserve, allowing a 4 minute reserve time. Since 

the aircraft will never fly more than 1.5 KM from the point of intended landing, a full battery 

charge at launch will ensure that I meet the reserve energy requirement of this paragraph. I 

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

“energy". 

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 my intention that the PIC perform maintenance and inspection of the aircraft and "be 

authorized to approve the aircraft for return to service." As provided in the Pre-Flight Checklist 

in Appendix A, 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. I feel that due to the size, 

construction, and simplicity of the aircraft, the PIC can ensure an equivalent level of safety. 
8900.227 Paragraph 16(c)(4) PIC Medical. and Paragraph 16(e)(1) Observer Medical. 

This policy provides that both the PIC and VO must have a valid FAA second-class medical 

certificate issued under part 67 in order to perform as a pilot or observer. 

The sUAS maximum gross weight is 2935 g, it is constructed of carbon fiber and plastic and 

the PIC is not on board. Both the PIC and the VO are required to be in VLOS. Given the unlikely 

event that both the PIC and VO become medically incapacitated while the aircraft is in flight, the 

UA will return autonomously to the site of launching and land without crew intervention. 

Therefore, requiring the PIC and VO to meet the same medical requirements as a commercial 

pilot carrying passengers in a large aircraft is an unnecessary burden.

I propose that the minimum medical requirements for the PIC and VO be vision corrected to 

20/20 and a valid, state issued driver's license. The 20/20 vision requirement will ensure that the 

PIC and VO can see and avoid air traffic; a licensed driver is medically qualified to operate a 

much larger vehicle. Although I maintain a 3rd class medical to support my other ratings I don’t 

feel a 3rd class medical is necessary for safe operations of this sUAS