1

UNITED STATES OF AMERICA 

DEPARTMENT OF TRANSPORTATION 

FEDERAL AVIATION ADMINISTRATION 

WASHINGTON, DC

Regulatory Docket No. 

IN THE MATTER OF THE PETITION FOR EXEMPTION OF: 

BLUESUIT TECHNOLOGY, LLC.

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 a) DJI INSPIRE 1UNMANNED AIRCRAFT 

SYSTEMS PURSUANT TO SECTION 333 OF

THE FAA MODERNIZATION AND REFORM ACT OF 2012 

(PUBLIC LAW 112-95)

Submitted on July 10, 2015

BLUESUIT TECHNOLOGY, LLC 

Sheila Walker, President

8855 Villa Ridge Drive #1323

Fort Worth, TX 76108

682-235-7390

info@bluesuitechnology.com
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TABLE OF CONTENTS

Page

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

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

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

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

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

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

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

TECHNOLOGY, LLC SEEKS EXEMPTION......................................................7

THE EXTENT OF RELIEF BLUESUIT TECHNOLOGY, LLC SEEKS AND THE 

REASON BLUESUIT TECHNOLOGY, LLC SEEKS THE RELIEF...........................10

THE REASONS WHY GRANTING BLUESUIT TECHNOLOGY, LLC’S REQUEST 

WOULD BE IN THE PUBLIC INTEREST ...................................................................13

THE REASONS WHY GRANTING THE EXEMPTION WOULD NOT ADVERSELY 

AFFECT SAFETY............................................................................................................15

CONCLUSION.................................................................................................................28
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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) 

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

BLUESUIT TECHNOLOGY, LLC 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 BLUESUIT TECHNOLOGY, LLC to operate an 

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

video and photography for real estate photography, wedding videography, special 

events, film sets and landscape over certain areas of the United States.

INTRODUCTION AND INTERESTS OF THE PETITIONER

My name is Sheila Walker, Owner/President of BLUESUIT TECHNOLOGY, 

LLC. It is my mission to provide my clients with expertise and knowledge in all 

aspects of picture, video & audio production, as well as provide them with advanced 

technologies & solutions that will increase efficiency, productivity and effectiveness. 

BLUESUIT TECHNOLOGY, LLC, also provides clients with the highest quality 

digital content for use in their commercial, personal, and non-profit multimedia 

projects. BLUESUIT TECHNOLOGY, LLC has several years of professional 

experience in photography and videography and has become recognized as an expert in 

this field. BLUESUIT TECHNOLOGY, LLC has 2 years of building expertise in aerial 

video and photography. The objective of BLUESUIT TECHNOLOGY, LLC’s aerial 

video and photography operations is to provide high quality imaging for a variety of 

commercial, public, and residential uses, specifically targeting:

• Real Estate Videography and Photography

• Wedding Videography and Photography

• Land survey & appraisals

• Equipment Inspections

• Roof Inspections

• Construction sites before & after

• Precision Agriculture

• Creation of commercial messages for Television

• Search and Rescue operations in cooperation with local law enforcement

• Motion Picture Filming

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

Unmanned Aircraft System: DJI Inspire 1 UAS

BLUESUIT TECHNOLOGY, LLC seeks an exemption to operate DJI systems for 

compensation or hire within the NAS. The DJI Inspire 1 are 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 are equipped with four main rotors; driven by Lithium Polymer battery 

powered electric motors.

The DJI Inspire 1 UA that will be operated by BLUESUIT TECHNOLOGY, LLC

will be registered in accordance with 49 U.S.C. 44103, Registration of Aircraft, as well 

as 14 C.F.R Part 47, Aircraft Registration, and marked in accordance with 14

C.F.R. Part 45, Identification and Registration Marking.

BASIS FOR PETITION

Petitioner, BLUESUIT TECHNOLOGY, LLC, 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, BLUESUIT TECHNOLOGY, LLC

operation of DJI Inspire 1 UAS meets the conditions of FMRA Section 333 and

therefore, will not require an airworthiness certificate in accordance with 14 C.F.R. 

Part 21, Subpart H.

Accordingly, BLUESUIT TECHNOLOGY, LLC 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.

BLUESUIT TECHNOLOGY, LLC submits that the requested relief is proper since 

an equivalent level of safety will be ensured. BLUESUIT TECHNOLOGY, LLC 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, DJI Inspire 1 

Instruction Manual). Furthermore, BLUESUIT TECHNOLOGY, LLC, will document 

and maintain all maintenance records for the DJI Inspire 1 UAS.
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Relief from certain requirements of Section 61.113(a) and (b), entitled Private pilot 

privileges and limitations: Pilot in command, is requested by BLUESUIT 

TECHNOLOGY, LLC to the extent necessary to allow a Pilot in Command (PIC) 

holding a private pilot or higher level certificate, as well as an airman medical 

certificate, and who has demonstrated, by meeting minimum flight- hour and currency 

requirements, that the PIC is able to safely operate the DJI Inspire 1 UAS in a manner 

consistent with this exemption, including evasive and emergency maneuvers and 

maintaining appropriate distances from people, vessels, vehicles and structures.

BLUESUIT TECHNOLOGY, LLC seeks relief from Section 91.7(a), entitled Civil 

aircraft airworthiness, because the DJI Inspire 1 UAS do not require an airworthiness 

certificate in accordance with 14 C.F.R. Part 21, Subpart H. As such, BLUESUIT 

TECHNOLOGY, LLC submits that they will ensure that the DJI Inspire 1 UAS are in 

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

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

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

BLUESUIT TECHNOLOGY, LLC also seeks an exemption from the requirements 

of Section 91.121, entitled Altimeter Settings, as the DJI Inspire 1 UA will not have a 

typical barometric altimeter onboard. However, altitude information of the DJI Inspire 

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 

BLUESUIT TECHNOLOGY, LLC’s 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, BLUESUIT TECHNOLOGY, LLC seeks an exemption from the 

requirements of Section 91.151(b), entitled Fuel requirements for flight in VFR 

conditions. BLUESUIT TECHNOLOGY, LLC 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, BLUESUIT TECHNOLOGY, LLC 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: 

Sheila Walker c/o BLUESUIT TECHNOLOGY, LLC.

8855 Villa Ridge Drive #1323

Fort Worth, TX 76108

Tel: (682) 235-7390

Email: info@bluesuitechnology.com
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B. The Specific Sections Of 14 C.F.R. From Which BLUESUIT TECHNOLOGY,

LLC Seeks Exemption.

1. BLUESUIT TECHNOLOGY, LLC Seeks Exemption From The 

Requirements Of Section Part 21, Subpart H

14 C.F.R. Part 21, Subpart H, establishes the procedural requirements for the 

issuance of airworthiness certificates as required by 14 C.F.R. §91.203(a)(1)

2. BLUESUIT TECHNOLOGY, LLC 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.

3. BLUESUIT TECHNOLOGY, LLC 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.

4. BLUESUIT TECHNOLOGY, LLC 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
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(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.

5. BLUESUIT TECHNOLOGY, LLC 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.

6. BLUESUIT TECHNOLOGY, LLC 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[.]

7. BLUESUIT TECHNOLOGY, LLC 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[.]

8. BLUESUIT TECHNOLOGY, LLC 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.
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9. BLUESUIT TECHNOLOGY, LLC Seeks Exemption From The 

Requirements Of Sections 91.417(a) And 91.417(b).

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

following:

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

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

specified in paragraph (b) of this section:

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

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

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

airframe) and each engine, propeller, rotor, and appliance of an aircraft. 

The records must include--

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

the work performed; and

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

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

aircraft for return to service.

(2) Records containing the following information:

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

and each rotor.

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

propeller, rotor, and appliance.

(iii) The time since last overhaul of all items installed on the aircraft which

are required to be overhauled on a specified time basis.

(iv) The current inspection status of the aircraft, including the time since

the last inspection required by the inspection program under which 

the aircraft and its appliances are maintained.

(v) The current status of applicable airworthiness directives (AD) and 

safety directives including, for each, the method of compliance, the

AD or safety directive number and revision date. If the AD or safety 

directive involves recurring action, the time and date when the next

action is required.

(vi) Copies of the forms prescribed by § 43.9(d) of this chapter for each

major alteration to the airframe and currently installed engines, rotors, 

propellers, and appliances.

(b) The owner or operator shall retain the following records for the periods 

prescribed:

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

until the work is repeated or superseded by other work or for 1 year after

the work is performed.

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

and transferred with the aircraft at the time the aircraft is sold.

(3) A list of defects furnished to a registered owner or operator under § 43.11

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

aircraft is approved for return to service.
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C. The Extent Of Relief BLUESUIT TECHNOLOGY, LLC Seeks And The Reason 

BLUESUIT TECHNOLOGY, LLC Seeks The Relief.

1. BLUESUIT TECHNOLOGY, LLC Seeks Exemption From The Requirements 

Of Section Part 21, Subpart H

Given the size and limited operating area associated with the UAS to be utilized by 

BLUESUIT TECHNOLOGY, LLC, an exemption from Part 21 Subpart H meets the 

requirements of an equivalent level of safety under Part 11 and Section 333 of the 

Reform Act.

The Federal Aviation Act (49 U.S.C.§ 44701(f)) and Section 333 of the Reform Act both 

authorize the FAA to exempt aircraft from the requirement for an airworthiness 

certificate, upon consideration of the size, weight, speed, operational capability, and 

proximity to airports and populated areas of the particular UAS.

In all cases, an analysis of these criteria demonstrates that the UAS operated without an 

airworthiness certificate, in the restricted environment and under the conditions proposed 

will be at least as safe, or safer, than a conventional rotorcraft operating with an 

airworthiness certificate without the restrictions and conditions of the proposed UAS 

operations.

2. Extent Of Relief BLUESUIT TECHNOLOGY, LLC Seeks And The Reason 

BLUESUIT TECHNOLOGY, LLC 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, BLUESUIT TECHNOLOGY, LLC submits that an 

equivalent level of safety will be maintained because no PIC will be allowed to operate 

the DJI Inspire 1 UAS unless that PIC has met certain flight-hour and currency 

requirements, demonstrating that the PIC is able to safely operate either the DJI Inspire 

1 UAS in a manner consistent with the operations specifications as described in this 

exemption, including evasive and emergency maneuvers, as well as maintaining 

appropriate distances from people, vessels, vehicles and structures.
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Further, BLUESUIT TECHNOLOGY, LLC 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 

BLUESUIT TECHNOLOGY, LLC.' business; and (2) will not carry passengers or 

property for compensation or hire.

3. Extent Of Relief BLUESUIT TECHNOLOGY, LLC Seeks And The Reason 

BLUESUIT TECHNOLOGY, LLC 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 BLUESUIT TECHNOLOGY, LLC to determine that the DJI Inspire 1 

UAS are in airworthy condition prior to every flight by ensuring that the UAS

is in compliance with the operating documents (i.e., Monthly Maintenance Log, DJI 

Inspire 1 Instruction Manual).

BLUESUIT TECHNOLOGY, LLC seeks the requested relief because the DJI Inspire 1 

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

Subpart H. Therefore, BLUESUIT TECHNOLOGY, LLC will ensure that the DJI 

Inspire 1 UAS are in airworthy condition based upon its compliance with the operating 

documents (i.e., Monthly Maintenance Log, 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.

4. Extent Of Relief BLUESUIT TECHNOLOGY, LLC Seeks And The Reason 

BLUESUIT TECHNOLOGY, LLC Seeks Relief From Section 91.121.

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

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

equipment, and a radio communications telemetry data link to downlink altitude 

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

requires that any altitude information concerning UAS operations be reported to air 

traffic control (ATC) in feet above ground level (AGL), BLUESUIT TECHNOLOGY, 

LLC seeks the requested relief because the DJI Inspire 1 UA altimeter may be set on the 

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

before each flight.

Considering the limited altitude of the proposed operations, relief from 14 CFR 91.121 is 

sought to the extent necessary to comply with the applicable conditions and limitations 

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

maintained since the DJI Inspire 1 UA are equipped with a barometric pressure sensor 

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

be established prior to each flight, and provides the PIC with altitude information of the 

UA on the heads-up display of the GCS.
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5. Extent Of Relief BLUESUIT TECHNOLOGY, LLC Seeks And The Reason 

BLUESUIT TECHNOLOGY, LLC 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. 

BLUESUIT TECHNOLOGY, LLC 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 BLUESUIT TECHNOLOGY, LLC proposes to conduct pursuant 

to this Petition.

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

DJI Inspire 1 operating documents, and BLUESUIT TECHNOLOGY, LLC.’s proposed 

operating limitations, ensure that BLUESUIT TECHNOLOGY, LLC 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.

6. Extent Of Relief BLUESUIT TECHNOLOGY, LLC Seeks And The Reason 

BLUESUIT TECHNOLOGY, LLC 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, BLUESUIT TECHNOLOGY, LLC

requests relief from these Sections because the DJI Inspire 1 UAS do not require 

airworthiness certificates. As set forth more fully below, the DJI Inspire 1 UAS meet the 

conditions of FMRA Section 333 for operation without an airworthiness certificate. 

Accordingly, BLUESUIT TECHNOLOGY, LLC 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, DJI Inspire 1 Instruction Manual). Furthermore, BLUESUIT 

TECHNOLOGY, LLC will document and maintain all maintenance records for the DJI 

Inspire 1 UAS.
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D. The Reasons Why Granting BLUESUIT TECHNOLOGY, LLC 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 BLUESUIT

TECHNOLOGY, LLC to safely, efficiently, and economically perform aerial video and 

photography of, real estate, wedding films, special events, precision agriculture, land 

survey & appraisal, construction sites, equipment & roof inspections, film sets, search and 

rescue and landscape 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 

BLUESUIT TECHNOLOGY, LLC’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 are battery powered and serve as a safe, efficient, and economical

alternative to the manned aircraft traditionally utilized to obtain aerial imagery. By 

reducing the amount of manned aircraft needed to perform aerial acquisitions, an 

exemption allowing the use of a or 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 do not require an airport to takeoff or land.

Likewise, a reduction of manned aircraft conducting aerial video and photography 

missions would result in fewer aircraft that must be handled by air traffic control during 

the ground, takeoff, departure, arrival, and landing phases of flight operations.

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

UAS.

Conducting aerial acquisitions with the DJI Inspire 1 UAS, instead of manned aircraft, 

will greatly benefit the public by drastically reducing the levels of air and noise pollution 

generated during traditional aerial video and still photography flight operations. By using 

battery power and electric motors, the DJI Inspire 1 UAS produce no air pollution, and is 

the most viable environmentally conscious alternative to the cabin class, six cylinder 

internal combustion engine aircraft that are typically utilized for aerial video and 

photography, while burning approximately 20-30 gallons per hour of leaded aviation fuel. 

The DJI Inspire 1 UA, while reducing the carbon footprint of aerial acquisitions, also 

eliminates noise pollution, as the UA are propelled by battery powered electric motors, 

rather than an internal combustion engine.
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By using the DJI Inspire 1 UAS to perform aerial acquisitions, the substantial risk to life 

and property in the air and on the ground, which is usually associated with traditional 

manned aircraft flight operations, will be substantially reduced or completely eliminated. 

Aside from the lack of flight crew members located onboard the aircraft, the DJI Inspire 1 

UA (weighing approximately 2 pounds 11 ounces and 6 pounds 7.5 ounces respectively, 

at their maximum gross weights with lengths of 16 inches and 17.3 inches respectively, 

widths of 16 inches and 17.7 inches respectively, 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 are 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 

BLUESUIT TECHNOLOGY, LLC, 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 BLUESUIT TECHNOLOGY, 

LLC, 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.

4. There Are No Privacy Issues.

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

decades, BLUESUIT TECHNOLOGY, LLC 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., Monthly Maintenance Log, 

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.
15

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 BLUESUIT TECHNOLOGY, LLC Seeks

Exemption.

1. Reasons Why The DJI Inspire 1 UA Meet The Conditions Of The FAA 

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

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

unmanned aircraft and its operation, BLUESUIT TECHNOLOGY, LLC operation of the 

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

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

Section 333 provides authority for a UAS to operate without airworthiness certification 

and sets forth requirements for considering whether a UAS will create a hazard to users 

of the NAS or the public, or otherwise pose a threat to national security. Specifically, 

FMRA Section 333 states the following, in part:

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

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

Transportation shall determine if certain unmanned aircraft systems may 

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

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

by section 334 of this Act.

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

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

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

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

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

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

a threat to national security; and

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

airworthiness certification under section 44704 of title 49, United 

States Code, is required for the operation of unmanned aircraft 

systems identified under paragraph (1).

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

section that certain unmanned aircraft systems may operate safely in the 

national airspace system, the Secretary shall establish requirements for the 

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

In seeking this exemption, BLUESUIT TECHNOLOGY, LLC 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 1UAS; (b) the pilot certification 

requirement; and (c) the specific operating limitations.
16

a. The Specifications Of The DJI Inspire 1 UAS Demonstrate Its Safe Characteristics.

The DJI Inspire 1 UAS 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 UAS. 

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

Specifications and Data Sheet, attached hereto as Exhibit A. 

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

The UAS To Remain Within A Defined Operational Area.

The DJI Inspire 1 UAS may be operated in both manual and fully autonomous flight 

modes. A complete description of the flight and navigational modes of the DJI Inspire 1 

UAS are provided at pages 12-18 and 45-52 of the DJI Inspire 1 User Manuals, attached 

hereto as Exhibit B.

iii. The DJI Inspire 1 UAS Are Designed For Automatic Return To Home Point Or 

Hover In The Event Of Loss Of The Control Link Or Navigation.

When the Control Link is lost, the DJI Inspire 1 UA will remain stationary, in flight, for 

3 seconds or more. If, after 3 seconds, the DJI Inspire 1 UA do 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 shutdown. A complete description of the Failsafe Functions for the DJI 

Inspire 1 at pages 13 through 15 of the DJI Inspire 1 User Manual, attached hereto as 

Exhibit 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 24 through 34 of the DJI Inspire 1 User 

Manual. DJI Inspire 1 User Manuals are attached hereto as Exhibits 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.

BLUESUIT TECHNOLOGY, LLC 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.
17

c. Flights Of DJI Inspire 1 UAS Will Be Conducted Pursuant To Specific Operating 

Limitations.

In seeking this exemption, BLUESUIT TECHNOLOGY, LLC proposes to 

commercially operate DJI Inspire 1 UAS for the special purpose of conducting 

aerial video and photography over certain areas of United States, pursuant to the 

following specific operating limitations:

1. Operations authorized by this grant of exemption will be limited to the following 

aircraft described in the operating documents, rotorcraft UAS weighing less than 55 

pounds maximum gross weight: DJI Inspire 1 Unmanned Aircraft Systems. Proposed 

operations of any other aircraft will require a new petition or a petition to amend this 

grant.

2. UAS operations under this exemption will be limited to conducting operations for the 

purpose of aerial video and photography.

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

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

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

special request is made and approved by ATC. All altitudes reported to ATC must be in 

feet AGL.

5. The UA must be operated within visual line of sight (VLOS) of the PIC at all times. 

This requires the PIC to be able to use human vision unaided by any device other than 

corrective lenses, as specified on the PIC’s FAA-issued airman medical certificate.

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.
18

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.

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.
19

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 

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.
20

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.

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).
21

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.

BLUESUIT TECHNOLOGY, LLC 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 or 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 BLUESUIT TECHNOLOGY, LLC’s proposed area of operations, 

and the operating limitations set forth-above; the parallel nature of private pilot 

aeronautical knowledge requirements to those of commercial pilot requirements (See 

Exemption No. 11062); and the airmanship skills necessary to safely operate the DJI 

Inspire 1 UAS, BLUESUIT TECHNOLOGY, LLC submits that the additional manned 

airmanship experience of a commercially certificated pilot would not correlate to the 

airmanship skills necessary for BLUESUIT TECHNOLOGY, LLC’s 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).

BLUESUIT TECHNOLOGY, LLC 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.
22

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 BLUESUIT TECHNOLOGY, LLC’ 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 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, BLUESUIT TECHNOLOGY, LLC will ensure safe operations by not 

allowing any PIC to operate the or 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.
23

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, BLUESUIT TECHNOLOGY, LLC will ensure that the 

DJI Inspire 1 UAS is in an airworthy condition based upon the UAS 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 BLUESUIT TECHNOLOGY, LLC’ operation of the DJI 

Inspire 1 UA within visual line of sight, at or below 500 feet AGL, will ensure a level of 

safety equivalent to Section 91.121. The altitude information will be generated by GPS 

equipment installed onboard the aircraft. Prior to each flight, a zero altitude initiation 

point is automatically established by the UAS at ground level.

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

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

Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11112, 11136, 11138,

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

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

Would Not Adversely Affect Safety.

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, BLUESUIT TECHNOLOGY, LLC 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.
24

Here, as in Exemption No. 11109, the technical specifications of the DJI Inspire 

1 UAS; the limitations on the proposed flight operations; and the location of the 

proposed operations, will ensure an equivalent level of safety established by 14 C.F.R. 

Section 91.151(b). Furthermore, safety will be ensured as the DJI Inspire 1 UAS

provide audible and visual warnings to the PIC at the GCS when the UA experiences 

low battery voltage, the first warning occurring at approximately 33% remaining 

battery power, and again at approximately 10% remaining battery power. At the 

critically low battery level, the DJI Inspire 1 UAS will descend and land automatically.

Significantly, previous exemptions granted by the FAA concerning Section

91.151 establish that safety is not adversely affected when the technical characteristics

and operating limitations of the UAS are considered. Relief has been granted for manned 

aircraft to operate at less than the minimums prescribed in Section 91.151, including 

Exemption Nos. 2689, 5745, and 10650. Moreover, the FAA has previously granted

relief from Section 91.151 specific to UAS, in circumstances similar, in all material

respects, to those presented herein (e.g. Exemption Nos. 8811, 10808, 10673, 11042,

11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11136, 11138, 11150,

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

6. Reasons Why An Exemption From The Requirements Of Sections 91.405(a),

91.407(a)(1), 91.409(a)(1) & (a)(2), And 91.417(a) & (b) Would Not Adversely Affect

Safety.

In seeking this exemption, BLUESUIT TECHNOLOGY, LLC 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 BLUESUIT TECHNOLOGY, LLC will use trained 

technicians to perform maintenance, alterations, or preventive maintenance on the UAS

using the methods, techniques, and practices prescribed in the operating documents (i.e., 

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

BLUESUIT TECHNOLOGY, LLC 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, BLUESUIT TECHNOLOGY, LLC will maintain the equivalent level of 

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

DJI Inspire 1 User Manual is attached hereto as Exhibit B; a copy of the DJI Inspire 1 

UAS Maintenance LOG is attached hereto as Exhibit C.

Likewise, the exemption sought will not adversely affect safety because 

BLUESUIT TECHNOLOGY, LLC 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.
25

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 BLUESUIT TECHNOLOGY, LLC’s proposed operating 

limitations, the operating documents, and the technical aspects of the DJI Inspire 1 

UAS, BLUESUIT TECHNOLOGY, LLC 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, BLUESUIT 

TECHNOLOGY, LLC 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 UA 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:
26

If the FAA finds that the airworthiness regulations of this subchapter do not contain

adequate or appropriate safety standards for an aircraft, aircraft engine, or propeller 

because of a novel or unusual design feature of the aircraft, aircraft engine or propeller, 

he prescribes special conditions and amendments thereto for the product. The special 

conditions are issued in accordance with Part 11 of this chapter and contain such safety 

standards for the aircraft, aircraft engine or propeller as the FAA finds necessary to 

establish a level of safety equivalent to that established in the regulations.

See 14 C.F.R. § 21.16. Therefore, in accordance with FMRA Section 333 and 14 C.F.R. § 

21.16, the FAA may prescribe special conditions for Leading Edge’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 BLUESUIT TECHNOLOGY, LLC Seeks

Exemption:

BLUESUIT TECHNOLOGY, LLC 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 BLUESUIT 

TECHNOLOGY, LLC Seeks:

This exemption will permit BLUESUIT TECHNOLOGY, LLC to commercially operate 

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

photography over certain areas of the United States.
27

Any Additional Information, Views, Or Arguments Available To Support 

BLUESUIT TECHNOLOGY, LLC’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, BLUESUIT TECHNOLOGY, 

LLC’s request for exemption may be granted pursuant to the authority of FMRA Section 

333 and 14 C.F.R. Part 11, as set forth above. FMRA Section 333 sets forth the 

requirements for considering whether a UAS will create a hazard to users of the NAS or 

the public, or otherwise pose a threat to national security; and further, provides the 

authority for such UAS to operate without airworthiness certification. As discussed in 

detail above, BLUESUIT TECHNOLOGY, LLC will operate the DJI Inspire 1 UAS

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

otherwise pose a threat to national security.
28

CONCLUSION

As set forth herein, BLUESUIT TECHNOLOGY, LLC seeks an exemption

pursuant to 14 C.F.R. § 11.61 and Section 333 of the FAA Modernization and

Reform Act of2012 (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

BLUESUIT TECHNOLOGY, LLC 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, 

BLUESUIT TECHNOLOGY, LLC 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)(l), 91.409(a)(l) & (a)(2), and 91.417(a) & (b), and 

permit BLUESUIT TECHNOLOGY, LLC Leading Edge to operate the

DJI Inspire 1 UAS commercially for the purpose of conducting aerial

video and photography over certain areas of the United States.

Dated: July 9, 2015

Respectfully submitted,

Sheila Walker

Sheila Walker, President

BLUESUIT TECHNOLOGY, LLC

8855 Villa Ridge Drive #1323

Fort Worth, TX 76108

Tel: (682) 235-7390

Appendices:

A -DJI Inspire 1 Specifications Data Sheet

B -DJI Inspire 1 Manufacturer's User Manual

C -Monthly Maintenance Log
29

APPENDIX – A

TECHNICAL SPECIFICATIONS

DJI INSPIRE 1 

BLUESUIT TECHNOLOGY, LLC only utilizes safe and reliable UAS. DJI is an 

industry leader in small UAS production. DJI UAS 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

1.1.1 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

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

1.1.1.1 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 - ±0.030

1.1.2.5 Mounting – Detachable

1.1.2.6 Controllable Range – Pitch: -900 to +300; Pan: ±3200

1.1.2.7 Mechanical Range – Pitch: -1250 to 450; Pan: ±3300

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

1.1.3 Camera

1.1.3.1 Name – X3

1.1.3.2 Model – FC350

1.1.3.3 Total Pixels – 12.76M
30

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
31

APPENDIX - B

DJI Inspire 1 Manufacturer’s User Manual 

User manual can be found at: 

http://www.dji.com/product/inspire-1/download
32

APPENDIX - C

MONTHLY MAINTENANCE LOG

month:' ''year:''

UAS(#:(

Date'Issue' 

Discovered

Date'Issue' 

Addressed Issue''Description'&'Maintenance'Conducted

Maintenance'Performed'by:'' 

Print'&'Sign

Software'Updates

Airframe

Engines

Propellers

Camera'Gimbal

Landing'Gear

Vibration'Dampening

Other: