g

, 

p

H; 14 CFR § 91.203(a)(1);14 CFR Part 27: 14 CFR §§ 91.9(c}, 

45.23(b) and 45.27(a);14 CFR § 61.113 (a) & (b);14 CFR § 91.7(a); 

91.9(b)(2); 91.103; 91.109(a); 91.119; 91.121; 91.151(a); 91.203 (a) 

& (b); 91.405(a); 91.407(a)(1 ); 91.409(a)(2); 91.417 (a) & (b) 

Dear Sir or Madam: 

Pursuant to Section 333 of the FAA Modernization and Reform Act of 

2012 ("Reform Act") and 14 CFR Part 11, P3 Communications 

("Petitioner"), a cellular network consulting and testing company that 

performs telecommunications interference inspection, hereby applies 

for an exemption from Federal Aviation Regulations ("FARs") 

identified below, to allow commercial operation of small unmanned 

aerial systems ("sUAS") so long as such operations are conducted 

within and under the conditions outlined herein or as may be 

established by the FAA as required by Section 333. 1 

This exemption is in accordance with protocols outlined in this petition 

for exemption, protocols defined in the following proprietary and 

confidential documents: 

I. Exhibit A P3 Operating Manual 

II. Exhibit 8 P3 Pre Flight Check List 

Ill. Exhibit C DJI Maintenance Manual 

1 The conditions proposed by the applicant are drawn from Order 8900.1 CHG 0, Volume 3 
y 

p

The principals of P3 have been in the business of 

telecommunications tower interference inspection for 5 (five) years for 

P3 Communications Inc., and its parent company P3 Group. Through 

that experience, the principals have developed a strong safety 

culture. 

Currently, inspection of telecommunication and utility structures can 

require employees to climb the structures or towers. Alternatively, the 

necessary assessment must be performed with techniques which are 

not as accurate. Inspection climbs involve the largest risk to 

personnel safety. On average since 2003, there have been 10 

wireless telecom tower fatalities per year in the US. 

P3 intends to utilize sUAS technology to reduce risks and improve the 

quality of their inspections by first utilizing the Inspire 1 to determine if 

there is a malfunction on the tower, if there is interference from a 

nearby source and what the source of the 3rd party interference is. 

P3's service includes RF propagation and service quality 

measurements for all cellular network technologies (GSM, UMTS, 

COMA, EVDO, L TE, WiFi, WiMax, 5G, P25, Tetra, etc.). 

Environments can include venues such as stadiums or other 

areas/routes of interest, where airborne RF coverage measurements 

are required. Automated measurement equipment is attached to the 

UAV to collect and store appropriate information while airborne for 

further post-processing. 

Another aspect of P3's proposed operations under this exemption 

would be the assessment of RF coverage and radio propagation This 

work would be performed prior to installing new transmitter e.g. in 

venues or other indoor and outdoor locations. The UAV will be used 

to temporarily place and hold a transmitter at certain geographical 
p

g

p

described in the above paragraphs. 

Also, congruent with the other operations P3 will provide flight 

instructions, training and proficiency training to employees 

incorporated in the UAS program. All flying will be performed by or 

under the control of a PPL (or UAS pilot certificate, when applicable). 

The petitioner intends the sUAS Pilot in Command (PIC) to have 

either a private pilot license (PPL) or an Unmanned Aircraft System 

(UAS) certificate (when it is available). They also intend to use a 

Safety Officer (SO) to act as an on-site observer for each mission. 

The PIC will hold a Class Ill medical. Both PIC and SO have unique 

training specific to the DJI Inspire 1 operations. 

Consistent with the requirements of 14 CFR § 11.81 (a), Petitioner 

provides the following information in support of its petition for 

exemption: 

The name and address of the Petitioner is: 

Michael Schwab 

VP, Network Testing 

P3 Communications 

412 Mt. Kemble Ave Suite G20s 

Morristown, NJ 07960 

1-973-944-8541 

Michaei.Schwab@p3-group.com 

II. Relevant Statutory Authority 

This petition for exemption is submitted to fulfill Congress• goal in 

passing Section 333(a) through (c) of the Reform Act. In the Reform 
q

In making this determination, the Secretary shall determine, at a 

minimum: 

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

their size, weight, speed, and 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 ). 

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" (Emphasis added).2 

In addition, the FAA Administrator has general authority to grant 

exemptions from its safety regulations and minimum standards when 

the Administrator decides a requested exemption is in the public 

interest. See 49 U.S.C. § 44701 (f) (authorizing the grant of 

exemptions from a requirement of regulations prescribed pursuant to 

section 44701(a)-(b) and sections 44702-44716). A party requesting 

an exemption must explain the reasons why the exemption: (1) would 

benefit the public as a whole, and; (2) would not adversely affect 

safety (or how it would provide a level of safety at least equal to the 

existing rules). See 14 CFR § 11.81; FAA, Petition for Exemptions. 

2 Section 333 places the duty on the Administrator, inter alia, to craft conditions for the safe operation of the UAS, if it should be determined that the conditions set forth herein do not fulfill the statutory 

requirements for approval. 
p

y 

by 1 00' radius surrounding the telecommunications, utility structure or 

constructions of interest and under 400' AGL. The sterile area 

confines the aircraft to airspace that is not currently navigable by 

manned aircraft per 14 CFR 91.119. Such operations will insure that 

the sUAS will "not create a hazard to users of the NAS or the public." 

Given the small size of the DJI Inspire 1 and the restricted sterile 

environment within which it will operate, the petitioner falls squarely 

within the zone of safety (an equivalent level of safety) in which 

Congress envisioned that the FAA must, by exemption, allow 

commercial operations of UASs to commence immediately. Also due 

to the size of the UASs and the restricted areas in which the relevant 

Inspire 1 sUAS will operate, approval of the application presents no 

national security issue. 

Given the clear direction in Section 333 of the Reform Act, the 

authority contained in the Federal Aviation Act, as amended; the 

strong equivalent level of safety surrounding the proposed operations 

and the significant public benefit of dramatically increased safety of 

aviation versus non-aviation inspection services associated with 

allowing sUAS technology to support P3 operations, the grant of the 

requested exemptions is in the public interest. Accordingly, the 

petitioner respectfully requests that the FAA grant the requested 

exemption without delay. 

Ill. Qualification for Approval Under Section 333 of the Reform 

Act 

The proposed operations in this petition for exemption qualify for 

expedited approval under Section 333 of the Reform Act. Each of the 

statutory criteria! and other potentially relevant factors are satisfied. 

The proposed operations would permit the use of small and relatively 
g (

) 

, 

g

g 

p

g 

payload specifically designed for safety and maximum ease of 

operation. It operates, under normal conditions, at a speed of no 

more than 43 KIAS and has the capability to hover, and move in the 

vertical and horizontal plane simultaneously. 

Petitioner's DJI Inspire 1 sUAS will operate in line-of-sight of the PIC 

and SO and will operate only within a sterile area surrounding objects 

that are current obstructions to navigable airspace for manned 

aircraft. Such operations will ensure that the DJIInspire 1 sUAS will 

.. not create a hazard to users of the National Airspace System or the 

public ... 

Given the small size of the sUAS involved and the restricted sterile 

flight operation environment, this petition for exemption falls squarely 

within the zone of safety i.e., an equivalent level of safety, in which 

Congress envisioned that the FAA must, by exemption, allow 

commercial operations of UASs to commence immediately. Also, due 

to the size of the UASs and the restricted areas in which the sUAS 

will operate, approval of the application presents no national security 

issue. 

Considering the clear direction in Section 333 of the Reform Act, the 

authority contained in the Federal Aviation Act, as amended, the 

equivalent level of safety surrounding the proposed operations, and 

the significant public benefit, including enhanced safety, reduction in 

environmental impacts, including reduced emissions associated with 

allowing UASs for the proposed operations, the grant of the 

requested exemptions is also in the public interest. 

Accordingly, Petitioner respectfully requests that the FAA grant the 

requested exemption without delay. 

IV. Description of Proposed Operations 
g

y 

p

regulatory guidelines: 

1. The Inspire 1 sUAS weighs less than 7 lbs. 

2. Flights will be operated within line-of-sight of the PIC and SO. 

3. Maximum total flight time for each operational flight will be 30 

minutes. Flights will be terminated at 27o/o battery power 

reserve should that occur prior to the 30 minute limit. 

4. Flights will be operated at an altitude of no more than 400 feet 

above ground level ("AGL"). 

5. Minimum crew for each operation will consist of the Inspire 1 

sUAS PIC and an SO. 

6. The PIC will be an FAA licensed airman with a private pilot's 

certificate or UAS certificate (when the FAA issues the criteria 

and procedures for a UAS license) and a third class medical 

certificate. 

7. The Inspire 1 sUAS pilot will be the PIC. If a pilot certificate 

holder other than the DJI Inspire 1 sUAS Pilot is present and 

possesses the necessary PIC qualifications, that person can 

also be designated as PIC. 

8. The OJI Inspire 1 sUAS will only operate within a confined by 

geo-fence to a sterile area defined by 1 00' radius surrounding 

the telecommunications or utility structure and under 400' AGL. 

9. A pre-flight briefing, in accordance with its Preflight Checklist 

(Exhibit B) will be conducted in regard to the planned Inspire 1 

sUAS operations prior to each flight mission. It will be 
requirements. Because operations are co

ed 

airspace already subject to the presence of personnel and 

equipment and the high number of forecast operations, 

Petitioner is requesting exemption from all FAA notification 

requirements. 

11. P3 will obtain consent of the PIC and SO to be at a point 

on the site, as proximate to the center of the proposed 

operations so that they will have a good visual line of sight 

throughout the operations. 

12. The PIC and SO will be trained in operation of DJI Inspire 

1 sUAS and will have received up-to-date maintenance and 

flight log information on the particular Inspire 1 sUAS to be 

operated, as required in Exhibits A and B. 

13. The PIC and SO will at all times be able to communicate 

by voice and/or text. 

14. Written and/or oral permission from the relevant property 

holders will be obtained. 

15. 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. 

16. If the Inspire 1 sUAS loses communications or loses its 

GPS signal, the Inspire 1 sUAS is equipped with advanced 

safety features that will allow the Inspire 1 sUAS to 

automatically return to a predefined location within the geefence perimeter. Failsafe Return to Home is activated 

automatically. If remote controller signal is lost for more than 3 

seconds it will return to a predefined location. 
The Federal Aviation Act expressly grants the FAA the aut

o

y 

issue exemptions. By its terms, this statutory authority includes 

exempting civil aircraft, as the term is defined under §401 01 of the 

Act, including sUAS, from its safety regulations and minimum 

standards when the Administrator decides a requested exemption is 

in the public interest. 

Petitioner seeks an exemption from several interrelated provisions of 

14 CFR Parts 21, 45 and 91 for purposes of conducting aerial 

surveys and inspections using sUAS. Listed below are: (1) the 

specific sections of 14 CFR for which exemption is sought; and (2) 

the operating procedures and safeguards that Petitioner has 

established which will ensure a level of safety equal to or better than 

the rules from which exemption is sought. 

Petitioner acknowledges that some of the below cited requests were 

addressed in FAA Order 11062 (Grant of Exemption to Astraeus 

Aerial, Docket FAA-2014- 0352) and for which no action was taken by 

the FAA. The FAA's analysis did, however, recite the petitioner's 

information as the basis for the no action; this Petition recites all of 

the previous sections for which exemptions were requested therein. 

A. 14 C. F.R. Part 21, Subpart H -Airworthiness Certificates & 

14 C. F.R. § 91.203(a) (1). 

This petition seeks an exemption from 14 CFR Part 21, Subpart H, 

which establishes the procedural requirements for the issuance of 

airworthiness certificates as required by 14 CFR §91.203(a)(1 ). 

Given the size, weight, speed and limited, obstructed and 

unpopulated operating area associated with the Inspire 1 sUAS to 

be utilized by the Petitioner, 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. 
p

p

13.22 pounds fully loaded, carries neither a pilot nor passenger, 

carries no explosive materials or flammable liquid fuels, and 

operates exclusively within a sterile area adjacent to structures 

that are considered obstructions to manned aircraft. Unlike other 

civil aircraft, aircraft operations will be tightly controlled and 

monitored by the PIC and SO pursuant to the P3 Exhibits A, B and 

C requirements and in compliance with local public safety 

requirements. Site security for the area of operation is consistent 

with existing requirements for maintaining public safety. 

Equivalent Level of Safety 

In all cases, an analysis of these criteria demonstrates that the DJI 

Inspire 1 sUAS 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 issued under 14 CFR Part 21, 

Subpart H. without the restrictions and conditions of the proposed 

DJIInspire 1 sUAS operations. The same criteria demonstrate 

that there is no credible threat to national security posed by the 

OJI Inspire 1 sUAS, due to its size, speed of operation, location of 

operation, lack of explosive materials or flammable liquid fuels and 

inability to carry a substantial external load. 

B. 14 C. F.R. Part 27: Airworthiness Standards: Normal 

Category Rotorcraft. 

14 CFR Part 27 sets forth the procedural requirements for 

airworthiness certification of normal category rotorcraft. To the 

extent the Petitioner's OJI Inspire 1 sUAS would otherwise require 

certification under Part 27, as a rotorcraft, Petitioner requests an 

exemption from Part 27's airworthiness standards for the same 

reasons identified in the exemption request from item A. 14 CFR 
identification requirements of 14 CFR §§ 91.9(c), 45.23(b) and 

45.27(a). 

14 CFR § 91.9(c), Civil aircraft flight manual, marking, and placard 

requirements, provides that: 

No person may operate a U.S.-registered civil aircraft unless 

that aircraft is identified in accordance with part 45 of this 

chapter. 

14 CFR § 45.23(b }, Markings of the Aircraft, states: 

When marks include only the Roman capital letter "N" and the 

registration number is displayed on limited, restricted or lightsport category aircraft or experimental or provisionally 

certificated aircraft, the operator must also display on that 

aircraft near each entrance to the cabin, cockpit, or pilot station, 

in letters not less than 2 inches nor more than 6 inches high, 

the words "limited," "restricted," "light-sport," "experimental," or 

"provisional," as applicable. 

14 CFR § 45.27(a), Rotorcraft, states: 

Each operator of a rotorcraft must display on that rotorcraft 

horizontally on both surfaces of the cabin, fuselage, boom, or 

tail the marks required by §45.23. 

Exemption from§ 45.23(b) is warranted because the DJI Inspire 1 

sUAS has no cabin, cockpit, or pilot station or entrance of any kind 

on which the word "Experimental" can be placed. Moreover, given 

the size of the DJI Inspire 1 sUAS, two-inch lettering would be 

impossible. The word "Experimental" will be placed on the 

fuselage in compliance with § 45.29(f). 
An equivalent level of safety for exemptions to the aircraft marking 

and identification requirements of§§ 91.9(c), 45.23(b) and 

45.27(a), will be provided by having the sUAS marked on its 

fuselage as required by §45.29(f) where the pilot, observer, and 

others working with the sUAS will see the identification of the UAS 

as "Experimental." Additionally, Petitioner will ensure compliance 

with any requests of sUAS marking by the FAA. 

The FAA has issued the following exemptions to the aircraft 

marking requirements of§ 45.23(b ): Exemptions Nos. 10700, 

8738, 10167 and 10167A. 

D. 14 C. F.R. § 61.113 (a) & (b): Private Pilot Privileges and 

Limitations: Pilot in Command. 

This petition seeks an exemption from the private pilot privileges 

and limitations of §61.113 (a) & (b), which states: 

Private pilot privileges and limitations: Pilot in command. 

(a) Except as provided in paragraphs (b) through (h) of this 

section, no person who holds a private pilot certificate may act 

as pilot in command of an aircraft that is carrying passengers or 

property for compensation or hire; nor may that person, for 

compensation or hire, act as pilot in command of an aircraft. 

(b) A private pilot may, for compensation or hire, act as pilot in 

command of an aircraft in connection with any business or 

employment if: 

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

and 
y

g p

g

p

p

y 

compensation or hire; nor may that person, for compensation or 

hire, act as pilot in command of an aircraft. 

A private pilot may, for compensation or hire, act as pilot in 

command of an aircraft in connection with any business or 

employment if: 

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

the aircraft does not carry passengers or property for 

compensation or hire. Section 61.113(a) limits private pilots to 

being in command of non-commercial flights. Section 61.113(b) (1) 

provides an exception that allows a private pilot to command an 

aircraft without passengers or property, in connection with 

business or employment if "the flight is only incidental to that 

business or employment." That exception likely does not apply to 

the proposed operations under this petition for exemption, as the 

flights are not incidental to the proposed aerial surveys and 

inspections but rather essential to it. Accordingly, this petition 

seeks an exemption to § 61.113(a)'s commercial limitation and/or 

§ 61.113(b) (1 )'s requirement that the flight be incidental to the 

business to benefit from the exception. 

Equivalent Level of Safety 

As required by the SOP (Exhibit B), Petitioner's DJI Inspire 1 

sUAS operators acting as PIC will hold a private pilot license or 

UAS pilot certificate (when the FAA issues the regulations for 

applying for a UAS pilot certificate) and manufacturers flight 

training specific to the Inspire 1 sUAS. Because the DJI Inspire 1 

sUAS will not carry a pilot or passengers, the proposed operations 

can achieve the equivalent level of safety to § 61.113 (a) and (b), 

by requiring the PIC operating the sUAS to have a private pilot 

license or UAS certificate and flight training specific to the DJI 
The level of safety provided by the requirements included in the 

P3 Exhibits A, 8 and C exceeds that provided by a single 

individual holding a commercial pilot's certificate operating a 

conventional aircraft in accordance with § 61.113 (a) & (b). The 

risks associated with the operation of small, lightweight UAS in an 

airspace adjacent to obstructions are diminished from the level of 

risk associated with commercial operations contemplated by Part 

61 when drafted, that allowing the proposed operations in this 

petition for exemption with a PIC holding a private pilot license or 

UAS pilot certificate exceeds the present level of safety achieved 

by §61.113 (a) & (b). 

E. 14 C. F.R. § 91.7(a): Civil Aircraft Airworthiness. 

This petition seeks an exemption from 14 CFR § 91.7(a), which 

requires that a civil aircraft be in an airworthy condition to be 

operated. Inasmuch there will be no airworthiness certificate 

issued for the sUAS, should this exemption be granted, no FAA 

regulatory standard will exist for determining airworthiness. 

Equivalent Level of Safety 

DJI's sUAS have over 700 commercial operators around the world 

and a stellar safety record. Given the size of the sUAS, the 

requirements contained in the P3 Exhibits A,8 and C, the training 

requirements of the PIC and SO and use of safety checklists prior 

to each flight, an equivalent level of safety will be provided. 

The FAA has issued the following exemptions to this regulation: 

Exemption Order 11062. 
(

) 

p

y 

p

g

(2) For which an Airplane or Rotorcraft Flight Manual is 

not required by 

§21.5 of this chapter, unless there is available in the 

aircraft a current approved airplane or Rotorcraft Flight 

Manual, approved manual material, markings, and 

placards, or any combination thereof. 

Given its size, configuration, and load capacity, the Inspire 1 sUAS 

has no ability to carry such a manual on the aircraft, not only 

because there is no pilot on board, but because there is simply no 

room or capacity to carry such an item on the aircraft. 

Equivalent Level of Safety 

The safety related purpose of this manual requirement can be 

equally satisfied by maintaining the Exhibit C DJI Inspire 1 Manual 

at the ground control point where the pilot flying the Inspire 1 

sUAS will have immediate access to it. Accordingly, Petitioner 

requests an exemption from§ 91.9(b) (2)'s flight manual 

requirements, on the condition that the Inspire 1 sUAS flight 

manual be available at the control point during each operation. 

The FAA has issued the following exemptions to this regulation: 

Exemption Order 11062. 

G.14 C. F.R. § 91.103: Preflight Action. 

This petition seeks an exemption from § 91.103, which requires a 

PIC to become familiar with specific information before each flight, 

including information contained in the FAA -approved Flight 

Manual on board the aircraft. In as much as an FAA approved 

flight manual will not be provided for the sUAS, an exemption will 
actions, including reviewing weather and NOT AMs, flight battery 

requirements, landing and takeoff distances, and aircraft 

performance data, before initiation of flight. 

H. 14 C. F.R. § 91.109(a): Flight Instruction. 

This petition seeks an exemption from 14 CFR § 91.109(a), which 

provides that: 

(a)No person may operate a civil aircraft (except a manned free 

balloon) that is being used for flight instruction unless that 

aircraft has fully functioning dual controls ... 

sUASs and remotely piloted aircraft, by their design do not have 

fully functional dual controls. Instead, flight control is accomplished 

through the use of a control box that communicates with the sUAS 

via radio communications. 

Equivalent Level of Safety 

Given the size and speed of the OJ I Inspire 1 sUAS, an equivalent 

level of safe training can still be performed without dual controls because no pilot or passengers are aboard the Inspire 1 sUAS, 

the system is equipped with an automatic come home feature that 

can be triggered at any time to respond to unpredicted challenges 

and all persons will be a safe distance away should the DJI Inspire 

1 sUAS experience any difficulties during flight instruction. 

Additionally, the aircraft's light weight and slow speeds with no 

pilot or passengers on board create less of a danger to the public 

than aircraft equipped with dual controls. 

The FAA has approved exemptions for flight training without fully 

functional dual controls for a number of aircraft and for flight 
q

§ 

p

minimum safe altitudes under which aircraft may not operate, 

including 500 feet above the surface and away from any person, 

vessel, vehicle, or structure in non-congested areas. See 14 CFR 

§ 91.119(c). Section § 91.119(d) (1) allows for a helicopter to 

operate at less than those minimum altitudes when it can be 

operated "without hazard to persons or property on the surface," 

provided that "each person operating the helicopter complies with 

any routes or altitudes specifically prescribed for helicopters by the 

FAA." 

To provide the intended telecommunication and utility structure 

inspections, the DJI Inspire 1 sUAS will normally need to be 

operated within a range of 100 feet laterally from the structure 

being inspected and under 400' AGL. Accordingly, due to the 

nature of the proposed operations, the PIC and the SO will be less 

than 100 feet away from structures during the operation, and an 

exemption is therefore required. 

Equivalent Level of Safety 

Compared to flight operations with rotorcraft weighting far more 

than the maximum 15 lbs. proposed herein, and the lack of 

flammable fuel, any risk associated with these operations is far 

less than those presently presented with conventional aircraft. An 

equivalent level of safety will be achieved given the size, weight, 

speed of the UAS as well as the location where it is operated. As 

set forth in the Exhibits A and B, the DJI Inspire 1 sUAS will be 

operated in a geo-fenced sterile area, where buildings and people 

will not be exposed to operations without their pre-obtained 

consent. No flight will be taken without the permission of the 

property owner and/or local officials. Because of the advance 

notice to the property owner and participants, all affected 

individuals will be aware of the planned flight operations as set 
This petition seeks an exemption from 14 CFR § 91.121, which 

requires a person operating an aircraft to maintain cruising altitude 

or flight level by reference to an altimeter that is set to the 

elevation of the departure airport or barometric pressure. An 

exemption is required because the DJI Inspire 1 sUAS does not 

have a barometric altimeter, but rather a GPS altitude read out. 

Equivalent Level of Safety 

An equivalent level of safety will be achieved by following the 

procedures set forth in the General Preflight Checklist in Exhibit B. 

As prescribed therein, the operator will confirm the altitude of the 

launch site shown on the GPS altitude indicator before flight. The 

flight plan will be programmed to maintain appropriate altitude 

above ground and under 400' AGL. Moreover, the PIC will use the 

GPS altitude indicator to constantly monitor the DJI Inspire 1 

sUAS's height, thus ensuring operation at safe altitudes. 

K. 14 C. F.R. § 91.151(a): Fuel Requirements for Flight in V F R 

Conditions. 

This petition seeks an exemption from 14 CFR § 91.151 (a)'s fuel 

requirements for flight in VFR conditions. Section 91.151 states: 

(a)No person may begin a flight in an airplane 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-

(1 )During the day, to fly after that for at least 30 minutes; or 

(2)At night, to fly after that for at least 45 minutes. 

The battery powering the DJIInspire1 sUAS provides less than 30 
30 minutes or 27

/o of battery power, whichever happens first. This 

restriction would be more than adequate to return the Inspire 1 

sUAS to its launch location from anywhere within its limited 

operating area. Operation of the DJI Inspire 1 sUAS with less than 

30 minutes of reserve fuel does not engender the type of risks that 

Section 91.151 (a) was intended to alleviate given the size and 

speed of the OJI Inspire 1 Moreover, operation will be limited to 

controlled areas where only people and property owners, or official 

representatives who have signed waivers will be allowed. 

This request for exemption falls within the scope of prior 

exemptions. See e.g. Exemption Order 11062 

L. 14 C. F.R. § 91.203 (a) & (b): Carrying Civil Aircraft 

Certification and Registration. 

This petition seeks an exemption from civil aircraft certification and 

registration requirements of 14 CFR § 91.203 (a) and (b). The 

regulation provides in pertinent part: 

(a)Except as provided in §91. 715, no person may operate a 

civil aircraft unless it has within it the following: 

(1 )An appropriate and current airworthiness certificate .... 

(b)No person may operate a civil aircraft unless the 

airworthiness certificate required by paragraph (a) of this 

section or a special flight authorization issued under §91. 715 

is displayed at the cabin or cockpit entrance so that it is 

legible to passengers or crew. 

In addition to the fact that Petitioner is seeking an exemption from 

the airworthiness certificate requirements, an exemption to this 

regulation is necessary because: 
Equivalent Level of Safety 

An equivalent level of safety will be achieved by keeping these 

documents; to the extent they are applicable to the DJI Inspire 1 

sUAS, at the ground control point where the pilot flying the Inspire 

1 sUAS will have immediate access to them. 

The FAA has issued numerous exemptions to this regulation. See, 

inter alia, Exemption Order 11062 

M.14 C. F.R. §§ 91.405(a); 91.407(a) (1); 91.409(a) (2); 91.417 

(a) & (b): Maintenance Inspections. 

This petition seeks an exemption from the maintenance inspection 

requirements of 14 CFR §§ 91.405(a); 91.407(a) (1 ); 91.409(a) (2); 

91.417 (a) & (b). 

These regulations specify maintenance and inspection standards 

in reference to 14 CFR Part 43. See, e.g., 14 CFR § 91.405(a) 

(stating that each owner or operator of an aircraft "[s]hall have that 

aircraft inspected as prescribed in subpart E of this part and shall 

between required inspections ... have discrepancies repaired as 

prescribed in part 43 of this chapter"). An exemption to these 

regulations is needed because Part 43 and these sections apply 

only to aircraft with an airworthiness certificate, which the DJI 

Inspire 1 sUAS will not have. 

Equivalent Level of Safety 

An equivalent level of safety will be achieved because 

maintenance and inspections will be performed in accordance with 

the Exhibit C DJI Inspire 1 V2 Manual. The operator will ensure 
, 

p

immediately and will be operating no higher than 400 feet AGL. 

Moreover, the Inspire 1 sUAS small size, carrying capacity, and 

the fact that flight operations will only take place in restricted areas 

for limited periods of time, create less risk than the same factors 

associated with conventional fixed-wing aircraft and rotorcraft 

performing the same operation. 

VI. Public Interest 

Consistent with the requirements of 14 CFR §11.81 (d), Petitioner 

offers the following reasons why granting this petition for exemption is 

in the public interest, i.e., how granting it would benefit the public as a 

whole. 

Approval of exemptions allowing commercial operations of small and 

lightweight sUAS in the utility aerial services industry benefits the 

public as a whole in the following ways: 

• It helps fulfill Congress' goal in passing Section 333(a) through 

(c) of the Reform Act, namely, the FAA Administrator's 

assessment of whether certain UAS may operate safely in the 

National Airspace System before completion of the rulemaking 

required under Section 332 of the Reform Act. 

• The operation significantly improves safety and reduces risk by 

alleviating human exposure to danger associated with current 

telecommunications interference inspection methods, namely, 

tower climbs. The public's interest is furthered by reducing 

human exposure to death or serious injury associated with 

personnel performing telecommunications interference 

inspections. As result of these safer, more efficient and more 

effective sUAS interference inspections, the nation will receive 

clearer more reliable telecommunications. 
equipment

e p

y 

g 

ecological impact of an accident and by reducing human 

exposure to emissions. 

• Visual surveys are valuable tools for telecommunications and 

utility structure inspections. However, the obstructed 

environment with cables and power lines impede aerial surveys 

and inspections from conventional manned aircraft. The use of 

the DJIInspire 1 sUAS addresses these problems and is a 

powerful tool for performing a wide-range of telecommunication 

and utility structure inspection and patrol applications. The 

public as a whole will benefit from the safer and more costeffective utility aerial services that Inspire 1 sUAS operations 

provide. 

VII. Privacy 

All flights will occur over Petitioner's property or the 

telecommunications and utility customer's property with the 

telecommunications or utility customer's prior consent and 

knowledge. 

VIII. Precedents 

The FAA has issued grants of exemption in circumstances 

similar in all material respects to those presented in the instant 

petition. In Grants of Exemption Nos. 11062 to Astraeus Aerial 

(see Docket No. FAA-2014-0352), 11109 to Clayco, Inc. (see 

Docket No. FAA-2014-0507), 11112 to VDOS Global, LLC 

(see Docket No. FAA-2014-0382), 11213 to Aeryon Labs, Inc. 

(see Docket No. FAA-2014-0642), and 12645 to Allied Drones 

(see Docket No. FAA-2014-0804), the FAA found that the 

enhanced safety achieved using an unmanned aircraft (UA) 

with the specifications described by the petitioner and carrying 

no passengers or crew, rather than a manned aircraft of 
g

y 

Petitioner requests that the FAA has determine that good cause 

exists for not publishing a summary of the petition in the Federal 

Register because the requested exemption would not set a 

precedent, and any delay in acting on this petition would be 

detrimental to the petitioner. 

X. Conclusion 

The Inspire 1 as a result of its size, weight, speed, operational 

capability, distance from airports and populated areas and operation 

within a contained area adjacent to obstacles within visual line of 

sight do not create a hazard to users of the national airspace system 

or pose a threat to national security. Adequate justification exists for 

the grant of the requested exemptions allowing commercial operation 

of P3 DJI Inspire 1 sUAS in the telecommunication and utility 

structure services industry in accordance with Exhibits A and B 

appended hereto. 

If additional information is required, or if you have any questions 

regarding this Petition for Exemption, please contact 

Michael Schwab 

VP Network Testing 

P3 communications 

412 Mt Kemble Avenue, 

Suite G20s 

Morristown, NJ 07960 

973 944 8541 

Michaei.Schwab@p3-group.com 

Respectfully submitted, 

p

p

OJ I Inspire 1 Dimensions: 438x451 x30 1 mm 

Diagonal Distance: 559 to 581 mm 

Weight: 2935g (Battery Included) 

• The DJI 1 Inspire is a stock T600, manufactured by 

OJI Innovations. It consists of one DJI 3510 motor, a 

Gimbal - model ZENMUSE X3, Camera- X3, (2) 

Remote Controllers --C 1, Charger - model A 14-

1 OOP 1 A, Battery - model TB4 7 . 

• The remote controller is a manufactured by DJI 

Innovations. The remote controller is powered by one 

battery. 

• The Inspire 1 is a quadcopter capable of capturing 4k 

video and transmitting an HD video signal (up to 2km) 

to multiple devices straight out of the box. Equipped 

with retractable landing gear, it can capture an 

unobstructed 360 degree view from its camera. The 

built-in camera has an integrated gimbal to maximized 

stability and weight efficiency while minimizing space. 

When no GPS signal is available, Vision Positioning 

technology provides hovering precision. 

Pre-flight Operations 

Upon removal from the travel case, the LPP will attach the 

landing gear and camera gimbal. Pre-flight inspection includes; 

props are secure and undamaged, all fasteners are tight and wires 

are secure and undamaged. The camera gimbal, camera and two 

batteries are mounted and secured. 

Warm-up Procedure 
g

p

q

g 

g 

green lights indicate ready for flight. An interface via laptop is 

attached to the flight controller to check sensor parameters and 

conduct calibrations. Following successful calibrations, the camera 

gimbal and video transmitter are powered up and tested. After all systems are powered and calibrated, a motor test and low level 

hover is conducted to test weight and balance. 

A step-by-step checklist is present for every DJI Inspire I flight and is 

included as Exhibit B. 

Pre-flight discussion 

Cellular Tower--A discussion will occur involving the Owner 

of the Site and of the Tower. P3's team will analyze and discuss 

weather conditions, obstacles and safety procedures. A set of 

flight parameters regarding altitude, speed of flight, length of flight, 

distance to be traveled and personnel required to be in the 

immediate vicinity will be determined. All this information will be 

announced during a site wide safety meeting. 

Flight 

Each flight will be conducted in a timely manner and conscious of any 

changing conditions. Prior arrangements with all relevant Air Traffic 

Control facilities will be carefully adhered to and the terms of issued 

NOTAMs will be reviewed and followed. 
Before Departing for Site Check 

I 

Aircraft (AC) and Remote Controller (RC) batteries fully charged 

I 

Tablet fully charged 

I 

Portable Radio for communicating with manned AC fully charged 

I 

Ensure SD card has free space and is inserted into the camera 

I 

Ensure Firmware is updated on AC and RC(s) 

I 

Cache location maps into all DJI Pilot app devices 

I 

Check for frequency (FX) used by local manned AC 

I 

Check if flight location is in No-Fly Zone 

I 

Program local FX into portable radio 

I 

Check for NOTAMs and Temporary Flight Restrictions (TFRs) 

I 

Check weather 

I 

Precipitation less than 5-10% 

I 

Winds under 20kts 
KP index is 5 or less 

I 

Check Sunrise, Sunset, Moonrise, Moonset 

Location On-Site Check 

I 

Check flying area free of overhead obstructions 

I 

I 

Wires, low flying AC, trees, tall buildings 

I 

Antennas that may interfere with compass and GPS reception 

Weather meets conditions 

I 

I 

Winds under 20 kts (23 MPH or 10 meters per second) 

I 

Clouds above 500' (152M) 

I 

Visibility for 1 statute mile 

I 

KP index 5 or less 

Confirm flight plan with camera operator and/or spotter 

Note: Still perform step if by oneself, it adds clarity to decision 

making. 

Physical Aircraft Check 

I 
I 

Motors clear of Foreign Object Debris (FOD) 

I 

Note: FOD may cause motor burnout and complete AC inversion 

on take-off 

Check propellers for any melting, misshapen, or cracks 

I 

Propellers hand tight 

I 

Prop locks firmly attached or 

I 

Quick Release plastic base has no cracks or fissures. 

Remote Controller Check 

I 

Antennas oriented Properly 

I 

Note: The broad side should face the AC and they should not 

touch each other. 

Switch to P-GPS mode 

I 

Landing gear switch oriented down 

I 

Check battery level of RC for minimum 75% 

DJI Pilot App Check 

I 
plan 

Note: 1 Meter= 3.3' 

r 

RC Signal Lost set to Return-to-Home 

r 

Check Sensors 

r 

r 

Gyroscope between "-1 . 0 to + 1 . 0" 

r 

Acceleration between "-1.0 to +1.0" 

r 

Compass MOD between "1400- 1599" 

r 

Check IMU 

Image Transmission Channel set 

r 

Note: Watch channels for 30 seconds to ensure selected channel 

is indeed stable 

Battery Cells all 4.28V or greater 

r 

r 

At least 98% battery 

r 

Ensure no greater than .2V between battery cells 

Adjust Gimbal Roll to make level 
I 

camera 

Turn all devices to airplane mode 

I 

Face AC into the wind 

I 

Note: This allows ACto float back to operator in case of 

emergency. 

Check heading of Aircraft 

I 

Note: Ensure nose heading of red paper airplane is close to nose 

heading of actual aircraft. 

Start Video recording 

I 

Start Propellers using a Combined Stick Command (CSC) 

I 

Ensure blue dot representing RC is accurately located on map 

I 

Ensure home point is accurately set on map 

I 

Ensure elevation reads 0 (zero) 
Maintenance Manual 

I. Checking the Battery 

1. Check the battery for damage and deformities. If there are any 

signs of damage to the battery, stop using it and discharge the battery 

to 1 0°/o or below for disposal. Do not disassemble the battery for any 

reason. 

2. Check the battery pins and rub them clean with an eraser if any 

residue is observed. This will help to ensure a more reliable 

connection. 

3. Check the metal battery power connectors for damage. This can be 

done by inserting a piece of sandpaper ( 1 mm think) into the 

connectors to polish the metal. 

4. Check the contact pins in the battery compartment to ensure that 

the pins are clear. They should be able to establish easy contact with 

the battery connectors and should not be bent. 

5. Check the electrodes on the battery. If they appear burnt, polish 

them with sandpaper. If there is serious erosion, send the battery in 

for repairs. 

6. Check the plastic components of the battery bracket to see it is in 

good condition and that all screws are secure. This prevents the 

battery from becoming loose during flight. 

7. Check the power cables between the arms and the center plate, if 

the cables are worn, contact DJI to arrange repairs. 

8. For long term storage, please refer to the "Intelligent Flight Battery 
g

, 

y

also check the battery cell warning history. If any warning are 

reported, contact DJI. 

II. Checking the Transformation System 

1. Check the servomotor cables for wear. Also confirm that the 

connection points are still in good condition. 

2. Check the lead screws and contact OJI Support to arrange repairs 

if any bending or damage is discovered. Clean the lead screws with 

WD-40 spray if they show signs of rust. 

3. Listen to the servomotors during the transformation, if there is 

abnormal noise, it may indicate that the servomotors worn. 

4. After the landing gear rises, check the lead screws and bearings. 

If any dirt or dust is found, clean and grease the bearings. 

5. Check the lead screws. If there are any scratches, dents, or 

plastic particles underneath them, contact DJI Support to arrange 

repairs. 

Ill. Checking the Aircraft 

1. Confirm that all the screws are still adequately tightened. 

2. Check the aircraft for breaks or damage. If there is any reason to 

believe that detectable damage might affect flight safety, consult with 

DJI Support. 

3. Check the carbon tubes of the arms for damage. 

4. Check the dampers on the landing gears. If they are loose, secure 
6. Check that the right and left landing gear rest at the same tilt angle. 

IV. Checking the Motors 

1. Check the rotors to confirm that they have not become loose. 

2. Detach the propellers and start the motors. Listen carefully. If 

there I any abnormal noise, please replace the motors. This may be a 

sign that the bearings have been worn out. 

3. Detach the propellers and start the motors. Carefully examine the 

edge of the rotor and confirm that the shaft is perfectly centered on 

the motor. Check for any abnormal or excessive vibration. If nay 

problems are detected, contact DJI Support to order replacement 

motors. 

4. Check for deformities by confirming that the gap between the motor 

and motor base is even. If not contact DJI Support to order 

replacement motors. 

5. Ensure that the screws used to secure the motor base are tight and 

the plastic components around the motors are in good condition. If 

not please tighten the screws and contact DJI to repair any broken 

plastic components. 

V. Checking the Propellers 

1. Check the propellers. If there is any bending, breakage or cracking 

on a propeller, do not use it. 

2. Attach the propeller to the motor, turn on the aircraft, and place it 

on the ground. Stand 1 meter away from the aircraft and observe the 
p

pp 

p

an advanced IMU calibration. Please place the aircraft in a cool 

environment and on a flat, stable surface (if the landing gear is 

damaged, support the aircraft with four objects of equal height. Do not 

touch the craft during the calibration. 

2. Turn on the aircraft and listen for any abnormal noise or vibration 

from the fan located on the front of the aircraft, If any irregularity is 

detected, replace the fan. 

VII. Checking the Control and Video Transmission System 

1. Check the 4 antennas on the landing gear to ensure that they are 

secure. Also check for any bending or damage. 

2. Check the antennas of the remote controller for damage. 

3. Check the neck strap for damage or wear, replace if necessary. 

VIII. Checking the Gimbal and Camera 

1. The quick-mount connector for the camera is a particularly 

vulnerable component. If the gimbal fails to initialize when turned on, 

fails to work after initialization, or fails to transmit video to the app 

(while OSD data is displayed), the quick-mount connector may be 

worn. In this case, replace the rubber mat, circuit board, and/or 

connector on the gimbal quick-mount. 

2. Check the metal contacts on the quick mount connector board, if 

any contact is bent, replace the quick-mount connector. 

3. Check the contact pins on the quick-mount connector board, if 

there is any dirt, rub it clean with an eraser. If any contact pins are 

worn out it should be replaced. 
ep

aced

IX. Checking the Vision Positioning System 

1. Check the lens of the camera. If any dirt or residue is detected, 

gently clean the lens. 

2. Check for and remove objects that might block the sensors. 

3. Ensure that the Vision Position System is securely installed on the 

aircraft. 

4. Detach the propellers and turn on the aircraft. Hold the aircraft 1-2 

meters above a surface with rich patters, under good lighting 

conditions. Change the Flight Mode switch toP Mode on the controller 

and check the OJI Pilot app. If the app displays an altitude value and 

indicates that P-OPTI mode is active, the Vision Positioning System 

should function normally.