March 14, 2016 

U.S. Department of Transportation

Docket Management System

1200 New Jersey Ave., SE Washington, DC 20590 

Re: Exemption Request Pursuant to Section 333 of the FAA Reform Act and Part 11 of the 

Federal Aviation Regulations from: 14 CFR 21 subpart H; 14 CFR 45.23(b); 14 CFR 61.113(a) 

and (b); 14 CFR 91.7(a); 14 CFR 91.9(b)(2); 14 CFR 91.103; 14 CFR 91.109; 14 CFR 91.119(c); 

14 CFR 91.121; 14 CFR 91.151(a); 14 CFR 91.203 (a) and (b); 14 CFR 91.405 (a); 14 CFR 

91.407 (a) (1) 14 CFR 91.409 (a)(1) and (2); 14 CFR 91.417(a) and (b) 

Dear Sir or Madam: 

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

14 CFR Part 11, Reynaldo Martin, DBA “Reynaldo Martin Studios, LLC,” operator of a DJI Inspire 

1 Unmanned Aircraft System (UAS), hereby applies for an exemption from the listed Federal 

Aviation Regulations (“FARs”) to allow commercial operation of designated UAS, provided such 

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

the FAA as required by Section 333. 

10679 Oak Bend Way 

Wellington, FL 33414
Commercial operation of an UAS, as described herein, which are equipped with camera(s) and 

sensors, would provide professional services in the following areas: 

1. Aerial photography and/or video for public and/or private use including real estate, architecture, 

land surveying, engineering and other related professional activities. 

2. Aerial video and/or photography for public and/or private use including television, public events, 

cinematography and newsgathering. 

3. Aerial inspection/photography of residential/commercial structures under contract with the owners 

or local government authority. 

4. Aerial inspection/photography of residential/commercial utility infrastructure including but not 

limited to electrical power lines, wind turbines and cell towers. 

5. Training to persons individually or belonging to both private and/or public organizations to 

increase awareness and improve safety for current and future UAS operations within the NAS. 

As described fully below, the requested exemption would permit the operation of designated UAS as 

set forth in this document under controlled conditions in the NAS that would be a) limited b) 

controlled c) predetermined and d) safe. Approval of this exemption would increase public 

awareness of UAS operations and enhance safety to aid in fulfilling the Secretary of Transportation’s 

(the FAA Administrator’s) responsibilities to “....establish requirements for the safe operation of such 

aircraft systems in the national airspace system.” 
The name and address of the applicant is: 

Reynaldo Martin, DBA “Reynaldo Martin Studios, LLC”

Ph: 954-817-9568

Email: info@reynaldomartin.com

Address: 10679 Oak Bend Way, Wellington, FL 33414 

Regulations from which the exemption is requested: 

14 CFR Part 21 subpart H 

14 CFR 45.23 (b)

14 CFR 61.113 (a) & (b) 

14 CFR 91.7 (a) 

14 CFR 91.9 (b) (2) 

14 CFR 91.103

14 CFR 91.109

14 CFR 91.119 (c) 

14 CFR 91.121 

14 CFR 91.151 (a)

14 CFR 91.203 (a) & (b) 

14 CFR 91.405 (a)

14 CFR 91.407 (a) (1) 

14 CFR 91.409 (a) (2) 

14 CFR 91.417 (a) & (b) 
Reynaldo Martin, DBA “Reynaldo Martin Studios, LLC”, will operate the following registered 

model UAS: 

DJI Inspire 1 (Registration N669AR) with the following specifications: 

AIRCRAFT 

Serial Number: W13DCD21031456 

Model: T600 

Weight (Battery Included): 2935 g 

Hovering Accuracy (GPS mode): Vertical: 0.5 m

Horizontal: 2.5 m 

Max Angular Velocity: Pitch: 300°/s

Yaw: 150°/s 

Max Tilt Angle: 35° 

Max Ascent Speed: 5 m/s 

Max Descent Speed: 4 m/s 

Max Speed: 22 m/s (ATTI mode, no wind) 

Max Service Ceiling Above Sea Level: 4500 m (Default altitude limit: 120 m above takeoff point) 

Max Wind Speed Resistance: 10 m/s 

Max Flight Time: Approximately 18 minutes 

Motor Model: DJI 3510H 

Propeller Model: DJI 1345T 

Indoor Hovering: Enabled by default 

Operating Temperature Range: -10° to 40° C 

Diagonal Distance: 559 to 581 mm 

Dimensions: 438x451x301 mm 

Power Spectral Density: 9.06mW/MHz

CAMERA 

Name: X3 

Model: FC350 

Total Pixels: 12.76M 

Effective Pixels: 12.4M 
Image Max Size: 4000x3000 

ISO Range: 100-3200 (video), 100-1600 (photo): 

Electronic Shutter Speed: 8s - 1/8000s 

FOV (Field of View): 94° 

CMOS: Sony EXMOR 1/2.3” 

Lens: 20mm (35mm format equivalent) f/2.8 focus at ∞

 9 Elements in 9 groups

Anti-distortion 

Still Photography Modes: Single shoot

 Burst shooting: 3/5/7 frames

 Auto Exposure Bracketing (AEB): 3/5 bracketed frames at 

0.7EV Bias 

Time-lapse 

Video Recording Modes: UHD (4K): 4096x2160p24/25, 3840x2160p24/25/30 

FHD: 1920x1080p24/25/30/48/50/60 

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

Max Bitrate of Video Storage: 60 Mbps 

Supported File Formats: FAT32/exFAT 

Photo: JPEG, DNG 

Video: MP4/MOV (MPEG-4 AVC/H.264) 

Supported SD Card Types: Micro SD 

Max capacity: 64 GB. Class 10 or UHS-1 rating required. 

Operating Temperature Range: 0° to 40° C

REMOTE CONTROLLER 

Name C1 

Operating Frequency 5.725~5.825 GHz 

2.400~2.483 GHz 

Maximum Transmitting Distance Up to 5 km or 3.1 miles (unobstructed, free of interference) 

when FCC compliant 

 Up to 3.5 km or 2.1 miles (unobstructed, free of 
interference) when CE compliant 

EIRP 10dBm@900m, 13dBm@5.8G, 20dBm@2.4G 

Video Output Port USB, mini-HDMI 

Power Supply Built-in battery 

Charging DJI charger 

Dual User Capability Host-and-Slave connection 

Mobile Device Holder Tablet or Phone 

Max Mobile Device Width 170mm 

Output Power 9 W 

Operating Temperature Range -10° to 40° C 

Storage Temperature Range Less than 3 months: -20° to 45° C 

More than 3 months: 22° to 28° C 

Charging Temperature Range 0-40° C 

Battery 6000 mAh LiPo 2S 

BATTERY (STANDARD) 

Name Intelligent Flight Battery 

Model TB47 

Capacity 4500 mAh 

Voltage 22.2 V 

Battery Type LiPo 6S High voltage battery 

Energy 99.9 Wh 

Net Weight 570 g 

Operating Temperature Range -10° to 40° C 

Storage Temperature Range Less than 3 months: -20° to 45° C 

More than 3 months: 22° C to 28° C 

Charging Temperature Range 5° to 40° C 

Max Charging Power 180 W

VISION POSITIONING 

Velocity Range Below 8 m/s (2 m above ground) 
Altitude Range 5-500 cm 

Operating Environment Brightly lit (lux > 15) patterned surfaces 

Operating Range 0-300 cm 

Given the small size of the UAS in scope and the controlled environment provided, the proposed 

operations will adhere to the Reform Act’s safety requirements. The approval of this application 

presents no national security issues. Regarding the level of safety surrounding the proposed 

operations and the public benefit, reduction in environmental impacts, including but not limited to 

reduced emissions and noise, the grant of the requested exemption is in the public interest. 

Accordingly, the applicant graciously requests that the FAA grant the requested exemption. 

AIRCRAFT AND EQUIVALENT LEVEL OF SAFETY 

The operation limitations proposed for an equivalent or higher level of safety because operations will 

further enhance the safety of the persons and/or property using conventional aircraft. These 

limitations and conditions to which the applicant agrees to adhere to when conducting commercial 

operations under the FAA issued exemption as set forth in the Flight Operations Manual (FOM) 

include: 

1. The UAS will weigh significantly less than 55 lbs. It weighs less than 7 pounds with battery and 

camera. 

2. The UAS will have a maximum operating speed of no more than 50 MPH. 

3. Flights will be operated within visual line of sight (VLOS) of the Pilot in Command (PIC) and/or 

Visual Observer (VO). The PIC will remain in command for the duration the flight and will not 

transfer his designation.

4. Maximum flight time for each operational flight will not exceed 18 minutes. Flights will be 

terminated at 25% battery power reserve or 15 minutes of flight time whichever occurs first. 

5. Flights will be operated at an altitude of no more than 400 feet Above Ground Level (AGL). 
6. Minimum crew for each operation will consist of the UAS Pilot and at least one Visual Observer 

(VO).

7. The UAS pilot will be a designated Pilot in Command (PIC) . The PIC will have logged a 

minimum of 20 hours on the designated UAS. 

8. A safety briefing will be performed prior to each day’s flights consisting of all the days’ 

production activities. 

9. All flight activities will be logged.

10. All flights will occur under Visual Flight Rules Meteorological Conditions (VMC) only. 

11. The flights will occur in Class G airspace no closer than a 5 mile radius of the geographic center/

Airport Reference Point (ARP) of a tower controlled or uncontrolled airport. 

12. Flights will not be closer than a 5 mile radius of the geographic center/Airport. 

13. If contracted for Motion Picture or Television Cinematography, The operator will obtain and 

abide by the motion picture and television operations manual (MPTOM). The operator will file FAA 

Form 7711, or its equivalent, as modified in light of the requested exemption, with the appropriate 

local Flight Standards District Office (FSDO) no more than 72 hours but no less than 48 hours from 

planned operation. 

14. If contracted for motion picture or television cinematography, flight operations will be conducted 

within 500 feet from participating consenting to be involved and necessary for the filming 

production, as specified by the MPTOM. 

15. The PIC and VO will have been trained in operation of UAS and receive up to date information 

for the particular UAS to be operated. 
16. The PIC and VO will be able to communicate by voice at all times. 

17. Written and/or verbal permission and permits will be obtained from territorial, state, county or 

city jurisdictions, including law enforcement, fire or other appropriate governmental agencies as 

appropriate to flight operations. 

18. If the UAS loses communications with the remote controller or loses GPS signal, the UAS will 

have the capability to return to a predetermined location within a designated location and land 

autonomously. 

19. The UAS will have the capability to abort a flight in case of emergencies with an automated 

“Return Home” and “Land” function. 

20. The UAS will have the capability to abort a flight in case of unpredicted obstacles, weather, or 

emergencies such as low battery. 

THE APPLICABLE LEGAL STANDARD UNDER SECTION 333 

Reynaldo Martin, dba “Reynaldo Martin Studios, LLC” submits that grant of this exemption 

application for use of the DJI Inspire 1 in precision aerial surveying, inspection, videography and 

photography will advance the Congressional mandate in Section 333 of the Reform Act to accelerate 

the introduction of UAS’s into the national airspace system (“NAS”) if it can be accomplished 

safely. This law directs the Secretary of Transportation to consider whether certain UASs may 

operate safely in the NAS before completion of the rulemaking required under Section 332 of the 

Reform Act. In making this determination, the Secretary is required to determine which types of 

UASs do not create a hazard to users of the NAS or the public or pose a threat to national security in 

light of the following: 

● The UAS’s size, weight, speed, and operational capability; 
● Operation of the UAS in close proximity to airports and populated areas; 

● Operation of the UAS within visual line of sight of the operator. 

Reform Act § 333(a)(1). If the Secretary determines that such vehicles “may operate safely in the 

national airspace system, the Secretary shall establish requirements for the safe operation of such 

aircraft in the national airspace system.” Id. §333(c). 

The Federal Aviation Act expressly grants the FAA the authority to issue exemptions. This statutory 

authority, by its terms, includes exempting civil aircraft, as the term is defined under §40101 of the 

Act, from the requirement that all civil aircraft must have a current airworthiness certificate and 

those regulations requiring commercial pilots to operate aircraft in commercial service: 

The grant of the requested exemption is in the public interest based on the clear direction in Section 

333 of the Reform Act; the additional authority in the Federal Aviation Act, as amended; the strong 

equivalent level of safety surrounding the proposed operations; and the significant public benefit, 

including enhanced safety and cost savings associated with transitioning to UAS’s for aerial 

surveying, photography, inspection and videography. Accordingly, the applicant respectfully requests 

that the FAA grant the requested exemption. 

Grant of the exemption to Reynaldo Martin, dba “Reynaldo Martin Studios, LLC” will be subject to 

the following mandatory conditions, which are based upon operating conditions set forth for 

operation of UAS by public entities pursuant to Certificates of Authorization, with additional 

restrictions: 

● All operations to occur in Class G airspace 

● Operations to avoid congested or populated areas, which are depicted in yellow on VFR charts 

● Operations to be conducted over private or controlled access property 
● Permission from land owner/controller required before commencing any flight 

● Operations to occur during Visual Flight Rules Meteorological Conditions (VMC) 

● Aircraft to remain within Visual Line of Sight (VLOS) 

● Operations to occur during daylight hours 

● Above Ground Level (AGL) altitude to be restricted to 400 feet 

● All operations conducted in vicinity of airport to remain more than 2.5 NM from centerline 

azimuth of runway centerline measured from runway thresholds 

● All required permissions and permits will be obtained from territorial, state, county or city 

jurisdictions, including local law enforcement, fire, or other appropriate governmental agencies 

OPERATOR REQUIREMENTS 

Reynaldo Martin, dba “Reynaldo Martin Studios, LLC” respectfully proposes that operator 

requirements should take into account the characteristics of the particular UAS. Certain UASs, such 

as the DJI Inspire 1, are characterized by a high degree of preprogrammed control and various builtin technical capabilities that limit the potential for operation outside of the operating conditions set 

forth above. 

The DJI Inspire 1 has a semiautonomous navigation and control system comprised of a Ground 

Control Station (GCS), GPS stabilization and autopilot system. In the case of unplanned events, the 

operator can allow the aircraft to follow the preprogrammed evasive maneuvers from the control unit 

or enable assisted steering for direct control. Preprogrammed maneuvers include initiation of holding 

at present position; and a Return to Home function that returns the aircraft to the launch point. 
Additional automated safety functions and safety enhancing features of the DJI Inspire 1 include the 

following: 

● Detection of lost GPS signal will initiate a return to home program, allowing the operator time to 

take control if necessary. 

● The GCS produces an audible message of the battery level when it reaches a predetermined 

threshold for safety (this can be adjusted). In the event the Aircraft is still airborne, the GCS 

initiates a program to land the aircraft safely before the battery is exhausted. 

● Onboard failsafe limits aircraft descent speed to a maximum of approximately 4 m/s. 

● The aircraft, weighing less than 7 lbs., fully loaded, is constructed of carbon fiber and high impact 

plastic or similar material, with shock absorption legs which is intended to absorb impact energy. 

● The aircraft has built in programmable Altitude and vertical distance limiter to ensure that flights 

are conducted within the parameters of the FOM.

In summary, applicant seeks an exemption from the FARs set forth above and in Appendix A to 

allow commercial operations of a small unmanned vehicle conducting aerial imaging, photography, 

videography, inspection and surveying. 

Approval of the exemption allowing commercial operations of the DJI Inspire 1 for aerial imaging, 

photography, videography, inspection and surveying work will enhance safety by reducing risk. 

Conventional aerial operations, using jet or piston-powered aircraft present risks associated with 

vehicles that weigh in the neighborhood of 5,000 to 7,000 lbs, carry large quantities of fuel, 

passengers, and, in some cases, cargo. Such aircraft must fly to and from the survey location. In 

contrast, an Inspire 1 weighing less than 7 lbs and powered by batteries eliminates a portion of that 

risk given the reduced mass and lack of combustible fuel carried on board. The DJI Inspire 1 is 

carried to the survey location, not flown there. The DJI Inspire 1 will carry no passengers or crew 

and, therefore, will not expose any individuals to the risks associated with manned aircraft flights. 
The operation of the DJI Inspire 1, weighing less than 7 lbs, for aerial imaging, photography, 

videography, inspection and surveying in accordance with the strict conditions outlined above, will 

provide an equivalent level of safety supporting the grant of the exemptions requested herein, 

including exempting Reynaldo Martin, dba “Reynaldo Martin Studios, LLC” from the requirements 

of Part 21. 

The DJI Inspire 1’s satisfaction of the criteria set forth in Section 333 of the Reform Act—size, 

weight, speed, operating capabilities, lack of proximity to airports and populated areas, operation 

within visual line of sight, and national security—and its showing of an equivalent level of safety as 

it may relate to the requirement for a pilot’s license, provide more than adequate justification for the 

grant of the requested exemptions allowing commercial operation of the DJI Inspire 1 in the 

commercial video and imaging business. 

Sincerely, 

Reynaldo Martin 

Owner, 

Reynaldo Martin Studios, LLC 

10679 Oak Bend Way 

Wellington, FL 33414 

Ph: 954-817-9568 

email: info@reynaldomartin.com