UNITED STATES OF AMERICA 

DEPARTMENT OF TRANSPORTATION 

FEDERAL AVIATION ADMINISTRATION 

WASHINGTON, DC 

Regulatory Docket No. _ 

IN THE MATTER OF THE PETITION FOR EXEMPTION OF:

Chesapeake Bay Helicopters, Inc.

FOR AN EXEMPTION SEEKING RELIEF FROM THE REQUIREMENTS OF 

TITLE 14 OF THE CODE OF FEDERAL REGULATIONS

SECTIONS 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1)

& (a)(2), AND 91.417(a) & (b) CONCERNING COMMERCIAL OPERATION OF THE 

DJI INSPIRE 1 UNMANNED AIRCRAFT SYSTEM

PURSUANT TO SECTION 333 OF

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

Submitted on May 8, 2015

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TABLE OF CONTENTS

Page 

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

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

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

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

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

NAME AND ADDRESS OF PETITIONER...................................................................7 

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

HELICOPTERS, INC. SEEKS EXEMPTION...............................................................8 

THE EXTENT OF RELIEF CHESAPEAKE BAY HELICOPTERS, INC. SEEKS AND 

THE REASON CHESAPEAKE BAY HELICOPTERS, INC. SEEKS THE RELIEF..11 

THE REASONS WHY GRANTING CHESAPEAKE BAY HELICOPTERS, INC.’S 

REQUEST WOULD BE IN THE PUBLIC INTEREST ..............................................14 

THE REASONS WHY GRANTING THE EXEMPTION WOULD NOT 

ADVERSELY AFFECT SAFETY ................................................................................17 

SUMMARY THAT CAN BE PUBLISHED IN THE FEDERAL REGISTER............32 

ANY ADDITIONAL INFORMATION, VIEWS, OR ARGUMENTS AVAILABLE 

TO SUPPORT CHESAPEAKE BAY HELICOPTERS, INC.’S 

REQUEST......................................................................................................................32

CONCLUSION.................................................................................................................33 
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GLOSSARY OF ABBREVIATIONS

AGL Above Ground Level 

AOI Area of Interest 

ATC Air Traffic Control 

ATO Air Traffic Organization 

C.F.R. Code of Federal Regulations 

COA Certificate of Authorization 

FAA Federal Aviation Administration 

FAR Federal Aviation Regulation 

FCC Federal Communications Commission 

GCS Ground Control Station 

GPS Global Positioning System 

NAS National Airspace System 

NOTAM Notice to Airmen 

PIC Pilot In Command 

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

SOP Standard Operating Procedures 

UA Unmanned Aircraft 

UAS Unmanned Aircraft System 

VFR Visual Flight Rules 

VLOS Visual Line of Sight 

VMC Visual Meteorological Conditions 

VO Visual Observer 

VTOL Vertical Takeoff and Landing 
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SUMMARY

CHESAPEAKE BAY HELICOPTERS, INC. seeks exemption from the requirements of 

14 C.F.R §§ 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & 

(a)(2), and 91.417(a) & (b), to operate an Unmanned Aircraft System pursuant to Section 333 of 

the FAA Modernization and Reform Act of 2012 (FMRA). This exemption will permit 

CHESAPEAKE BAY HELICOPTERS, INC.to operate an Unmanned Aircraft System (UAS) for 

the commercial purpose of conducting aerial data acquisitions within the National Airspace 

System (NAS) including, but not limited to the following industries; agriculture, oil and gas, 

aerial photography, wildlife preservation, filming for TV or movie production, and utility 

inspection. 

INTRODUCTION AND INTERESTS OF THE PETITIONER

CHESAPEAKE BAY HELICOPTERS, INC. (hereinafter referred to as “CBH”) provides 

manned helicopter-mounted advanced aerial data capture technologies, as well as manned 

helicopter-based construction and support services under FAR Part 133, which enable companies 

to operate more efficiently and achieve competitive advantages in their respective markets. 

BACKGROUND

Unmanned Aircraft System: DJI Inspire 1 UAS

CBH seeks an exemption to operate the DJI Inspire 1 UAS (Inspire 1 UAS) for 

compensation or hire within the National Airspace System (NAS). The Inspire 1 UAS is 

comprised of a vertical takeoff and landing (VTOL or helicopter) Unmanned Aircraft (UA) and a 

transportable Ground Control Station (GCS). The Inspire 1 UA has: a maximum gross weight of 

approximately 6.5 pounds; approximate dimensions of a length of 17 inches, width of 18 inches, 

and height of 12 inches; and maximum speed of approximately 43 knots. The Inspire 1 UA is 
5

equipped with four rotors, each driven by a Lithium Polymer battery powered electric motor. 

Complete technical data is contained within the attached manufacturer’s manuals. 

The Inspire 1 UA that will be operated by CBH 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, Chesapeake Bay Helicopters, Inc., 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 Inspire 1 UAS within 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 size, weight, speed, and limited operating area associated with the 

unmanned helicopter and its operation, CBH’s operation of the 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, CBH 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. 

CBH submits that the requested relief is proper since an equivalent level of safety will be 

ensured. CBH will perform maintenance, alterations, or preventive maintenance on the UAS 
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using the methods, techniques, and practices prescribed in the current operating and maintenance 

documents (i.e., the Inspire 1 UAS User Manual, the Inspire 1 Maintenance Manual, the Inspire 

1 UAS Quick Start Guide, the Inspire 1 UAS Safety Guidelines, the Intelligent Flight Battery 

Safety Guidelines), or will utilize manufacturer authorized support services to perform 

maintenance, alterations, or preventive maintenance on the UAS. Furthermore, CBH will 

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

Relief from certain requirements of Section 61.113(a) and (b), entitled Private pilot 

privileges and limitations: Pilot in command, is requested by CBH to the extent necessary 

to allow operation of the Inspire 1 UAS by a Pilot in Command (PIC) holding a private 

pilot 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 Inspire 1 UAS in a manner consistent with this exemption, including evasive 

and emergency maneuvers, as well as operating the helicopter without hazard to people, 

vessels, vehicles and structures in accordance with Section 91.119(d). 

CBH seeks relief from Section 91.7(a), entitled Civil aircraft airworthiness, because the 

Inspire 1 UAS does not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, 

Subpart H. As such, CBH submits that it will ensure that the Inspire 1 UAS is in an airworthy 

condition, prior to every flight, by determining that the UAS is in compliance with the current 

operating and maintenance documents (i.e., the Inspire 1 UAS User Manual, the Inspire 1 

Maintenance Manual, the Inspire 1 UAS Quick Start Guide, the Inspire 1 UAS Safety 

Guidelines, and the Intelligent Flight Battery Safety Guidelines), and that the aircraft is in a 

condition for safe flight. 
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CBH also seeks an exemption from the requirements of Section 91.121, entitled Altimeter 

Settings, because the altitude reporting equipment of the Inspire 1 UAS is set to zero feet above 

ground level (AGL), rather than local barometric pressure or field altitude, before each flight. 

The altitude information of the Inspire 1 UA is provided to the PIC via a barometric pressure 

sensor, Global Positioning System (GPS) equipment, and a radio communications telemetry data 

link, which downlinks from the UA to the GCS for active monitoring of the flight path. A level 

of safety equivalent to Section 91.121 will be ensured as the altitude of the Inspire 1 UA will be 

reported to air traffic control (ATC) in feet above ground level (AGL), and CBH will operate the 

Inspire 1 UA within visual line of sight. 

Additionally, CBH seeks an exemption from the requirements of Section 91.151(b), 

entitled Fuel requirements for flight in VFR conditions. CBH submits that safety will not be 

affected by operation of the 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 (i.e., 25 percent battery power remaining). 

In accordance with 14 C.F.R. § 11.81, CBH 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 is: 

CHESAPEAKE BAY HELICOPTERS, INC. 

Attn: Oleg Bulanov 

Ph: 757-465-9936 

Fax: 757-465-9946 

Email: olegbulanov@cbhelos.com 

Address: 5202 W Military Hwy, Bldg. 11 

Chesapeake, VA 23321 
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B. The Specific Sections Of 14 C.F.R. From Which CBH Seeks Exemption.

1. CBH Seeks Exemption From The Requirements Of Section 61.113(a) And (b).

Section 61.113, entitled Private pilot privileges and limitations: Pilot in command, 

 subsections (a) and (b) prescribe the following, in relevant part: 

(a) No person who holds a private pilot certificate may act as a pilot in command (PIC) of 

an aircraft that is carrying passengers or property for compensation or hire; nor may that 

person, for compensation or hire, act as PIC of an aircraft. 

(b) A private pilot may, for compensation or hire, act as PIC of an aircraft in connection 

with any business or employment if— 

(1) The flight is only incidental to that business or employment; and 

(2) The aircraft does not carry passengers or property for compensation or hire. 

2. CBH 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. 

3. CBH Seeks Exemption From The Requirements Of Section 91.121.

Section 91.121, entitled Altimeter settings, subsection (a), states the following, in part: 

(a) Each person operating an aircraft shall maintain the cruising altitude or flight level of 

that aircraft, as the case may be, by reference to an altimeter that is set, when operating-- 

(1) Below 18,000 feet MSL, to-- 

(i) The current reported altimeter setting of a station along the route and within 

100 nautical miles of the aircraft; 

(ii) If there is no station within the area prescribed in paragraph (a)(1)(i) of this 

section, the current reported altimeter setting of an appropriate available station; or 

(iii) In the case of an aircraft not equipped with a radio, the elevation of the 

departure airport or an appropriate altimeter setting available before departure; 
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4. CBH Seeks Exemption From The Requirements Of Section 91.151(b).

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

states the following: 

(b) No person may begin a flight in a rotorcraft under VFR conditions unless (considering 

wind and forecast weather conditions) there is enough fuel to fly to the first point of 

intended landing and, assuming normal cruising speed, to fly after that for at least 20 

minutes. 

5. CBH 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[.] 

6. CBH Seeks Exemption From The Requirements Of

Section 91.407(a)(1).

Section 91.407, entitled Operation after maintenance, preventive maintenance, 

 rebuilding, or alteration, subsection (a)(1), states the following: 

(a) No person may operate any aircraft that has undergone maintenance, preventive 

maintenance, rebuilding, or alteration unless-- 

(1) It has been approved for return to service by a person authorized under § 43.7 

of this chapter[.] 

7. CBH 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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8. CBH 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. 
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(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. 

C. The Extent Of Relief CBH Seeks And The Reason CBH Seeks The Relief.

1. Extent Of Relief CBH Seeks And The Reason CBH 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 

certificate, as well as a current and valid FAA issued 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, CBH submits that an equivalent level of safety will 

be maintained because no PIC will be allowed to operate the Inspire 1 UAS unless that PIC 

has met certain flight-hour and currency requirements, demonstrating that the PIC is able to 

safely operate the Inspire 1 UAS in a manner consistent with the operations specifications 

as set forth herein, including evasive and emergency maneuvers, as well as operating the 
12

helicopter without hazard to people, vessels, vehicles and structures in accordance with 

Section 91.119(d). 

Further, CBH submits that all flights of the Inspire 1 UAS, conducted by the PIC 

pursuant to the grant of this Petition: (1) will be incidental to CBH’ data acquisition 

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

2. Extent Of Relief CBH Seeks And The Reason CBH 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 CBH to determine that the Inspire 1 UAS is in an airworthy condition prior to 

every flight by ensuring that the UAS is in compliance with the current operating and 

maintenance documents (i.e., the Inspire 1 Maintenance Manual, the Inspire 1 UAS User Manual, 

the Inspire 1 UAS Quick Start Guide, the Inspire 1 UAS Safety Guidelines, and the Intelligent 

Flight Battery Safety Guidelines). 

CBH seeks the requested relief because the Inspire 1 UAS does not require an 

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

ensure that the Inspire 1 UAS is in an airworthy condition based upon its compliance with the 

operating and maintenance documents prior to every flight, and further, determine that the 

aircraft is in a condition for safe flight, as stated in the conditions and limitations below. 

3. Extent Of Relief CBH Seeks And The Reason CBH Seeks Relief From Section 

91.121.

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

operations of the Inspire 1 UAS, because the Inspire 1 UA’s altitude reporting equipment may be 

set on the ground to zero feet AGL, rather than local barometric pressure or field altitude, before 
13

each flight. The Inspire 1 UAS utilizes a barometric pressure sensor, GPS equipment, and a 

radio communications telemetry data link to downlink altitude information from the UA to the 

PIC at the ground control station (GCS). 

Considering the limited altitude of the proposed operations, relief from 14 C.F.R. § 

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

stated below. As more fully set forth herein, a level of safety equivalent to Section 91.121 will 

be ensured as the altitude of the Inspire 1 UA will be reported to air traffic control (ATC) in feet 

above ground level (AGL), and CBH will operate the Inspire 1 UA within visual line of sight. 

4. Extent Of Relief CBH Seeks And The Reason CBH 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 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 (i.e., 25 percent battery power remaining). 

CBH seeks the requested relief because without an exemption from Section 91.151(b), the flight 

time duration of the battery powered Inspire 1 UA will severely constrain the practicality of any 

aerial data acquisition and research flight operations that CBH proposes to conduct pursuant to 

this Petition. 

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

Inspire 1 UAS operating documents, and CBH’ proposed operating limitations, ensure that CBH 

will safely operate the battery powered 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 
14

normal cruising speed, to fly after that for at least 4.5 minutes (i.e., 25 percent battery power 

remaining). 

5. Extent Of Relief CBH Seeks And The Reason CBH 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, CBH requests relief from these Sections 

because the Inspire 1 UAS does not require an airworthiness certificate. As set forth more fully 

below, the Inspire 1 UAS meets the conditions of FMRA Section 333, for operation without an 

airworthiness certificate. Accordingly, CBH will perform maintenance, alterations, or 

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

the current operating and maintenance documents (i.e., the Inspire 1 Maintenance Manual, the 

Inspire 1 UAS User Manual, the Inspire 1 UAS Quick Start Guide, the Inspire 1 UAS Safety 

Guidelines, and the Intelligent Flight Battery Safety Guidelines), or will utilize manufacturer 

authorized support services to perform maintenance, alterations, or preventive maintenance on 

the UAS. Furthermore, CBH will document and maintain all maintenance records for the 

Inspire 1 UAS. 

D. The Reasons Why Granting CBH’s 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 CBH to safely, 

efficiently, and economically perform aerial data acquisitions within the NAS, commercially, in 

support of the various industries currently served by CBH’s manned helicopters. Additionally, use 

of the Inspire 1 UAS will decrease congestion of the NAS, reduce pollution, and provide 

significant benefits to the economy. Notably, the benefits of Chesapeake Bay Helicopters’ 

proposed operation of the Inspire 1 UAS will be realized without implicating any privacy issues. 

1. The Public Will Benefit From The Aerial Acquisitions Performed.
15

CBH submits this Petition to commercially operate the Inspire 1 UAS and perform 

aerial data acquisition within the NAS, in support of the various industries currently served by 

CBH’s manned helicopters. The Inspire 1 UAS will provide safe, efficient, and economical 

aerial data acquisition operations to further each of these industries, which are critical to the 

well-being of the general public. 

2. The Public Will Benefit From Decreased Congestion Of The NAS.

The Inspire 1 UA is battery powered and serves as a safe, efficient, and economical 

alternative to the manned aircraft traditionally utilized to obtain aerial data and/or imagery. By 

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

allowing the use of a Inspire 1 UAS would reduce the amount of manned aircraft in the NAS, 

reduce noise and air pollution, and 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 Inspire 

1 UA does not require an airport to takeoff or land. Likewise, a reduction of manned aircraft 

conducting aerial survey 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. 

3. The Public Will Benefit From The Safety And Efficiency Of The

Inspire 1 UAS.

Conducting aerial acquisitions with the 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 data acquisition operations. By using battery power and electric motors, 

the Inspire 1 UAS produces no air pollution, and is the most viable environmentally conscious 
16

alternative to the traditional manned helicopters that are typically utilized for aerial acquisitions, 

and burn approximately 20-50 gallons per hour of fuel. The Inspire 1 UA, while reducing the 

carbon footprint of aerial acquisitions, also reduces noise pollution, as the UA is propelled by 

battery powered electric motors, rather than an internal combustion engine. 

By using the 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 

helicopter flight operations, will be substantially reduced or completely eliminated. Aside from 

the lack of flightcrew members located onboard the helicopter, the Inspire 1 UA (weighing 

approximately 6.5 pounds at its maximum gross weight with a length of 17 inches, width of 18 

inches, and with no fuel on board), has less physical potential for collateral damage to life and 

property on the ground, and in the air, compared to the manned helicopters that typically conduct 

aerial acquisitions (weighing 3-6,000 pounds with a rotor diameter of 30-40 feet, and a fuel 

capacity of approximately 100 gallons). 

4. Performing Aerial Acquisition Operations With The Inspire 1 UAS Will

Benefit The Economy.

In addition to being safe and efficient, the Inspire 1 UAS is also an economical 

alternative to using manned helicopters to conduct aerial acquisitions. As such, operation of the 

Inspire 1 UAS will allow United States based companies, like CBH, 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 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. 
17

By operating the Inspire 1 UAS, companies such as CBH, 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 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. 

5. There Are No Privacy Issues.

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

its inception in 1998, CBH’s proposed operation of the Inspire 1 UAS will not implicate any 

privacy issues. Specifically, the Inspire 1 UAS will be operated pursuant to the specific 

conditions and limitations set forth herein, and in accordance with the Federal Aviation 

Regulations, including the minimum safe altitude requirements of 14 C.F.R. § 91.119(a) and (d) 

and without hazard to any person, vessel, vehicle, or structure. 

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 CBH Seeks Exemption.

1. Reasons Why The Inspire 1 UAS Meets 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, CBH’ operation of the Inspire 1 UAS meets the conditions 

of FMRA Section 333, and will not require an airworthiness certificate in accordance with 14 

C.F.R. Part 21, Subpart H. 
18

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, CBH submits that the Inspire 1 UAS can operate safely in 

the NAS pursuant to FMRA Section 333, as demonstrated by: (a) the characteristics of the 

Inspire 1 UAS; (b) the pilot certification requirement; (c) the specific operating limitations; 

and (d) the CBH “Standard Operating Procedures (SOP) And Policies” which contains 

proprietary information and is to be held in a separate file pursuant to 14 C.F.R. § 11.35(b). 

a. The Specifications Of The Inspire 1 UAS Demonstrate Its

Safe Characteristics.
19

The Inspire 1 UAS does 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 Inspire 1 UAS.

The technical specifications of the Inspire 1 UAS are set forth in the Inspire 1 User 

Manual, attached hereto as Exhibit A. 

ii. The Inspire 1 UAS Autonomous Flight And Navigation Modes

Enable The UAS To Remain Within A Defined Operational

Area.

The Inspire 1 UAS may be operated in both manual and autonomous flight modes. A complete 

description of autonomous flight modes is provided in the Inspire 1 User Manual, attached hereto 

as Exhibit A. 

iii. The Inspire 1 UAS Is Designed For Automatic Return To Home 

 Point Or Automatic Landing In The Event Of Loss Of

The Control Link Or Navigation.

A complete description of the Failsafe Functions of the Inspire 1 UAS is set forth at 

pages 13 through 17 of the Inspire 1 User Manual, attached hereto as Exhibit A. 

iv. The Inspire 1 GCS And Its Operation.

The Inspire 1 ground control station (GCS) is comprised of at least one remote controller, 

as well as a mobile device supporting the system software, known as the DJI Pilot App. A 

complete description of the operation and specifications of the Inspire 1 remote controller is 

provided at pages 23 through 33 of the Inspire 1 User Manual. A complete description of the 

operation and specifications of DJI Pilot App is provided at pages 40 through 43 of the Inspire 1 
20

User Manual. The Inspire 1 UAS is compliant with all Federal Communications Commission 

(FCC) requirements, and the radio frequency spectrum used for operation and control of the UA 

is set forth at page 58 of the Inspire 1 UAS User manual. 

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

The Line Of Sight Of A Certificated Pilot in Command With

A Safety Observer.

CBH will only utilize certificated pilots who possess a current and valid FAA issued 

airman medical certificate to act as a pilot in command (PIC) of the Inspire 1 UAS. 

Additionally, a safety observer will assist all pilots during flight operations. 
21

c. Flights Of The Inspire 1 UAS Will Be Conducted Pursuant To

Specific Operating Limitations.

In seeking this exemption, CBH proposes to commercially operate the Inspire 1 UAS for 

the special purpose of conducting aerial data acquisitions within the NAS, pursuant to the 

following specific operating limitations: 

1. Operations authorized by this grant of exemption are limited to the following aircraft 

described in the operating documents, a rotorcraft weighing 55 pounds or less at 

maximum gross weight: Inspire 1 Unmanned Aircraft System. 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 data acquisitions. 

3. The UA may not be flown at an indicated airspeed exceeding 43 knots. 

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

(AGL), as indicated by the procedures specified in the operating documents. 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 visual observer (VO) is not 

permitted. 

7. All operations must utilize a visual observer (VO). The VO may be used to satisfy the 

VLOS requirement as long as the PIC always maintains VLOS capability. The VO 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 VO can perform the functions prescribed in the operating documents. 

8. The VO must not perform any other duties beyond assisting the PIC with seeing and 

avoiding other air traffic and other ground based obstacles/obstructions and is not 

permitted to operate the camera or other instruments. 

9. The operating documents and the grant of exemption must be accessible during UAS 

operations and made available to the Administrator upon request. If a discrepancy exists 

between the conditions and limitations contained in the grant of exemption and the 

procedures outlined in the operating documents, the conditions and limitations contained 

in the grant of exemption take precedence and must be followed. Otherwise, the operator 
22

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 this exemption, 

then the operator must petition for amendment to the 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 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. 

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 
23

emergency maneuvers and as well as operating the helicopter without hazard to people, 

vessels, vehicles and structures in accordance with Section 91.119(d). PIC qualification 

flight hours must be logged in a manner consistent with 14 C.F.R. § 61.51(b). The VO is 

also required to complete the operator’s training requirements. A record of training must 

be documented and made available upon request by the Administrator. Flights for the 

purposes of training the operator’s PICs and VOs (training, proficiency, and experiencebuilding), 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 without hazard to nonparticipants in 

accordance with 14 C.F.R. § 91.119(d). 

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). 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. 

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 Airmen 

(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. 
24

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 under 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. The UA may not be operated over congested or densely populated areas. 

32. Flight operations must be conducted at an altitude that allows, if a power unit fails, an 

emergency landing without undue hazard to persons or property on the ground as per 14 

CFR 91.119(a). Additionally, the helicopter shall be operated without hazard to persons 

or property on the ground at all times as per 14 CFR 91.119(d). 

33. 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. 

34. 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. 

d. Operation Of The Inspire 1 UAS Will Be In Accordance

With Standard Operating Procedures And Policies.

“CBH Standard Operating Procedures (SOP) And Policies” will regulate CBH’ 

operation of the Inspire 1 UAS and will significantly contribute to maintaining the level of 

safety contemplated by the regulations from which CBH now seeks relief. 
25

The “CBH Standard Operating Procedures And Policies,” which contain proprietary 

information, are attached hereto as Exhibit F, and is to be held in a separate file pursuant to 

14 C.F.R. § 11.35(b). 

2. Reasons Why An Exemption From The Requirements Of Section 

61.113(a) And (b) Would Not Adversely Affect Safety.

CBH 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 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 Inspire 1 UAS in a manner consistent 

with the exemption, including evasive and emergency maneuvers, as well as operating the 

helicopter without hazard to people, vessels, vehicles and structures in accordance with 

Section 91.119(d) in the same manner as our manned helicopters. 

Considering CBH’ proposed area of operations, and the operating limitations set forthabove; 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 Inspire 1 UAS, CBH submits that the additional manned 

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

airmanship skills necessary for CBH’ 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, 11170, 11171, 11172). 
26

CBH will not allow any PIC to operate the Inspire 1 UAS unless that PIC has 

demonstrated, by meeting minimum flight-hour requirements or the Inspire 1 UAS training 

and currency requirements, that the PIC is able to safely operate the Inspire 1 UAS in a 

manner consistent with this exemption, including evasive and emergency maneuvers, as well 

as operating the helicopter without hazard to people, vessels, vehicles and structures in 

accordance with Section 91.119(d) in the same manner as our manned helicopters. 

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 including at least 10 

hours logged as a UAS pilot with a multi-rotor UAS (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 of the Inspire 1 UA 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 CBH’ 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 C.F.R. 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 
27

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, CBH will ensure safe operations by not allowing any PIC to operate the 

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 Inspire 1 UAS in a manner 

consistent with the exemption, including evasive and emergency maneuvers, as well as 

operating the helicopter without hazard to people, vessels, vehicles and structures in 

accordance with Section 91.119(d) in the same manner as our manned helicopters. 

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, CBH will ensure that the Inspire 1 UAS is in an airworthy 

condition based upon the UAS’s compliance with its operating documents and as stated in 

the proposed 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, 11166, 11167, 

11170, 11171, 11172). 
28

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 of the Inspire 1 UA will be reported to air traffic control (ATC) in feet 

above ground level (AGL), and CBH will operate the Inspire 1 UA within visual line of sight, 

at or below 400 feet AGL. Furthermore, the altitude information of the 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. 

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, 11166, 11167, 11170, 11171). 

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 Inspire 1 UAS; 

(2) the limitations on the proposed flight operations; and (3) the location of the proposed 

flight operations. Accordingly, CBH will ensure that it will safely operate the battery 

powered 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 (i.e., 25 percent battery power 

remaining). 
29

Here, as in Exemption No. 11109, the technical specifications of the 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 Inspire 1 UAS provides visual and audible 

warnings to the PIC at the GCS when the UA experiences low battery voltage, and if no 

action is taken in response to the warnings, the UA will automatically return to its starting 

point and land. A full description of the low battery level failsafes is provided at page 14 of 

the Inspire 1 User Manual, attached hereto as Exhibit A. 

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, 11166, 11167, 11170, 11171, 11172). 

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, CBH 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 CBH will 

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

techniques, and practices prescribed in the current operating and maintenance documents (i.e., 
30

the Inspire 1 Maintenance Manual, the Inspire 1 UAS User Manual, the Inspire 1 UAS Quick 

Start Guide, the Inspire 1 UAS Safety Guidelines, and the Intelligent Flight Battery Safety 

Guidelines), or will utilize manufacturer authorized support services to perform maintenance, 

alterations, or preventive maintenance on the UAS. Furthermore, CBH will document and 

maintain all maintenance records for the Inspire 1 UAS. 

Since the Inspire 1 UAS will be inspected as prescribed by the operating 

documents, CBH will maintain the equivalent level of safety established by Sections 

91.405(a), 91.409(a)(1), and 91.409(a)(2). The following operating and maintenance 

documents are attached hereto, identified as the following Exhibits: (A) the Inspire 1 

UAS User Manual; (B) the Inspire 1 UAS Quick Start Guide; (C) the Inspire 1 UAS 

Safety Guidelines; (D) the Intelligent Flight Battery Safety Guidelines; and (E) the 

Inspire 1 UAS Maintenance Manual. The foregoing exhibits contain proprietary 

information and are to be held in a separate file pursuant to 14 C.F.R. § 11.35(b). 

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

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

techniques, and practices prescribed by the operating documents, or will utilize 

manufacturer authorized support services to perform maintenance, alterations, or 

preventive maintenance on the UAS. 

Furthermore, the exemption sought would maintain an equivalent level of safety 

established by Sections 91.407, 91.417(a) and 91.417(b), because CBH will document and 

maintain maintenance records for the Inspire 1 UAS. 

In consideration of CBH’ proposed operating limitations, the operating documents, and 

the technical aspects of the Inspire 1 UAS, CBH 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), 
31

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, 11166, 11167, 11170, 11171, 

11172). 

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, CBH requests that the FAA 

prescribe special conditions for the intended operation of the 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 data acquisitions within the NAS 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 Inspire 1 UAS, since the airworthiness regulations of 14 C.F.R. 

Part21 do not contain adequate or appropriate safety standards, due to the novel or unusual 

design features of the aircraft. Section 21.16, entitled Special Conditions, states the following: 

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

adequate or appropriate safety standards for an aircraft, aircraft engine, or propeller 
32

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 CBH’ intended operation of the 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 CBH Seeks Exemption:

CHESAPEAKE BAY HELICOPTERS, INC. 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 CBH

Seeks:

This exemption will permit CHESAPEAKE BAY HELICOPTERS, INC.to 

commercially operate an Unmanned Aircraft System (UAS) for the purpose of 

conducting aerial data acquisitions within the National Airspace System (NAS).

G. Any Additional Information, Views, Or Arguments Available To Support CBH’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, CBH’ 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. 
33

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, CBH will operate the 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. CBH respectfully submits that because this small, unmanned aircraft 

system will be used in lieu of comparatively hazardous operations now conducted with our 

conventional manned helicopters, the FAA can have confidence that the proposed 

operations will achieve at least an equivalent or greater level of safety. Additionally, CBH 

already employs many policies and procedures that demonstrate a commitment to the safety 

of employees and the public in its helicopter operations, including an a v i a t i o n- b a s e d 

Safety Management System, FAA Approved FAR Part 133 Helicopter External Load 

operations and DOT drug and alcohol testing for safety-sensitive employees. Approval of this 

exemption would thereby enhance safety and fulfill the Secretary of Transportation’s (the 

FAA Administrator’s) responsibilities under Section 333(c) of the Reform Act to “establish 

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

CONCLUSION

As set forth herein, CBH seeks an exemption pursuant to 14 C.F.R. §11.61 and Section 333 of 

the FAA Modernization and Reform Act of 2012 (FMRA), which will permit safe operation of the 

Inspire 1 UAS commercially, without an airworthiness certificate, for the limited purpose of 

conducting aerial acquisitions within the National Airspace System (NAS). By granting this Petition, 

the FAA Administrator will be fulfilling the Congressional mandate of the FAA Modernization and 
34

Reform Act of 2012, while also advancing the interests of the public, by allowing CBH to safely, 

efficiently, and economically operate the 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, CBH respectfully requests that the 

Administrator grant this Petition for an exemption from the requirements of 14 C.F.R 

Sections 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & 

(a)(2), and 91.417(a) & (b), and permit CBH to operate the Inspire 1 UAS commercially for 

the purpose of conducting aerial acquisitions within the NAS.

Dated: May 8, 2015 

Respectfully submitted, 

Chesapeake Bay Helicopters, Inc.

/s/ Oleg Bulanov

Oleg Bulanov 

5202 West Military Hwy. 

Bldg. 11 

Chesapeake, VA 23321 

Tel: (757) 465-9936 

Fax: (757) 465-9946