UNITED STATES OF AMERICA 

DEPARTMENT OF TRANSPORTATION 

FEDERAL AVIATION ADMINISTRATION 

WASHINGTON, DC

Regulatory Docket No. 

IN THE MATTER OF THE PETITION FOR EXEMPTION OF:

Over SF LLC

FOR AN EXEMPTION SEEKING RELIEF FROM THE REQUIREMENTS OF 

TITLE 14 OF THE CODE OF FEDERAL REGULATIONS

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

91.409(a)(1) & (a)(2), AND 91.417(a) & (b) CONCERNING COMMERCIAL 

OPERATION OF DJI INSPIRE 1 PROFESSIONAL UNMANNED AIRCRAFT 

SYSTEM

PURSUANT TO SECTION 333 OF

THE FAA MODERNIZATION AND REFORM ACT OF 2012 (PUBLIC LAW 

112-95) 

Submitted on August 23rd, 2015

Over SF LLC

999 Green St. 

Suite #1101 

San Francisco, CA 94133

MailOverSF@gmail.com
TABLE OF CONTENTS

Page

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

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

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

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

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

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

THE SPECIFIC SECTIONS OF 14 C.F.R. FROM WHICH Over SF LLC

SEEKS EXEMPTION...............................................................................................8

THE EXTENT OF RELIEF Over SF LLC SEEKS AND THE REASON

Over SF LLC SEEKS THE 

RELIEF.........................................................................................10

THE REASONS WHY GRANTING Over SF LLC

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

THE REASONS WHY GRANTING THE EXEMPTION WOULD NOT 

ADVERSELY AFFECT SAFETY..............................................................................21

SUMMARY THAT CAN BE PUBLISHED IN THE FEDERAL REGISTER.........26

ANY ADDITIONAL INFORMATION, VIEWS, OR ARGUMENTS AVAILABLE 

TO SUPPORT Over SF LLC REQUEST.................................................................26

CONCLUSION....................................................................................................................27

APPENDICES........................................................................................28

Page 2 of 31
GLOSSARY OF ABBREVIATIONS

AGL Above Ground Level

AOI Area of Interest

ATC Air Traffic Control

ATO Air Traffic Organization

AV Aerial Vehicle

CFR Code of Federal Regulations

COA Certificate of Authorization

FAA Federal Aviation Administration 

FAR Federal Aviation Regulation 

GCS Ground Control Station

GPS Global Positioning System

LOL Loss of Link

NAS National Airspace System

NOTAM Notice to Airman

PIC Pilot In Command

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

SO Safety Observer

SOP Standard Operating Procedures

UA Unmanned Aircraft

UAS Unmanned Aircraft System

VFR Visual Flight Rules

VLOS Visual Line of Site

VMC Visual Meteorological Conditions

VTOL Vertical Takeoff and Landing

Page 3 of 31
SUMMARY

The petitioner 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 the petitioner to operate an Unmanned Aircraft System (UAS) for the commercial 

purpose of conducting aerial video and photography of construction sites, real estate, and 

landscape over certain areas of the United States. 

INTRODUCTION AND INTEREST OF THE PETITIONER 

Over SF LLC provides it’s clients a safe and unique solution to capture video and 

photography using Unmanned Aircraft Systems. The founder of Over SF LLC has over 11 

years of aviation experience. Including, an Air Transport Certificate, Certified Flight Instrument 

Instructor Certificate and over 5,000 hrs. of flight time in turbine powered multi-engine aircraft. 

As well as 3 years of recreational experience flying UASs systems that utilize both photo and 

video. 

The objective of The Petitioner's aerial video and photography operations is to 

provide high quality imaging for a variety of commercial, public, and 

residential uses, specifically targeting:

• Real-estate 

• Appraisals

• Construction Sites before and after

• Motion Picture Filming 

• Aerial acquisitions used for inspections of public and private structures 

• Search and Rescue operations

• Demonstrations 

• Mapping 

• Flight Instruction 

Page 4 of 31
BACKGROUND 

Over SF LLC seeks an exemption to operate DJI systems for compensation or hire 

within the NAS. The DJI Inspire 1 Professional UASs are vertical takeoff and landing 

(VTOL) Unmanned Aircraft (UA) with a Ground Control Station (GCS) utilizing 

electronic tablet or smart phone systems. The DJI Inspire 1 Professional has a maximum 

gross weight of approximately 6.5 pounds, while having a length of 18 inches, width of 

17 inches, height of 12 inches, and a maximum speed of approximately 43 knots. The DJI 

Inspire 1 Professional UAs are equipped with four main rotors; powered by Lithium

Polymer batteries and driven by electric motors.

The DJI Inspire 1 Professional UAs that will be operated by Over SF LLC will 

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

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

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

BASIS FOR PETITION 

The petitioner, pursuant to the provisions of the Federal Aviation Regulations 

(14 C.F.R. § 11.61) and the FAA Modernization and Reform Act of 2012 (FMRA), 

Section 333, Special Rules for Certain Unmanned Aircraft Systems, hereby petitions 

the Administrator to commercially operate the DJI Inspire 1 Professional UAs in the 

National Airspace System (NAS), and for an exemption from the requirements of 14 

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

91.409(a)(1) & (a)(2), and 91.417(a) & (b).

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

with the unmanned aircraft and its operation, the petitioner’s operation of DJI Inspire 1 

Professional 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, the petitioner 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.

Over SF LLC submits that the requested relief is proper since an equivalent level 

of safety will be ensured. The petitioner will use experienced personnel or technicians to 

perform maintenance, alterations, or preventive maintenance on the UASs using the 

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

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

petitioner will document and maintain all maintenance records for the DJI Inspire 1 

Professional UAs. 

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

privileges and limitations: Pilot in command, is requested by The Petitioner to the extent 

necessary to allow a Pilot in Command (PIC) not holding a certificate, or an airman 

Page 5 of 31
medical certificate, and who has demonstrated, by meeting minimum flight- hour and 

currency requirements, that the PIC is able to safely operate the 

DJI Inspire 1 Professional UASs in a manner consistent with this exemption, including 

evasive and emergency maneuvers and maintaining appropriate distances from people, 

vessels, vehicles and structures.

The petitioner seeks relief from Section 91.7(a), entitled Civil aircraft 

airworthiness, because the DJI Inspire 1 Professional UAs do not require an 

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

petitioner submits that they will ensure that the DJI Inspire 1 Professional UAs are in an 

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

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

Inspire 1 Professional Instruction Manual), and that the aircraft are in a safe condition for 

flight. 

The petitioner also seeks an exemption from the requirements of Section 

91.121, entitled Altimeter Settings, as the DJI Inspire 1 Professional UAs will not have a 

typical barometric altimeter onboard. However, altitude information of the DJI Inspire 1 

Professional UAs will be provided to the PIC via barometrically assisted Global 

Positioning System (GPS) equipment and radio communications telemetry data link, 

which downlinks from the UA to the GCS for active monitoring of the flight path. This 

altitude information, combined with the petitioner’s operation of the DJI Inspire 1 

Professional UAs within visual line of sight, at or below 400 feet AGL, will ensure a 

level of safety equivalent to Section 91.121. 

Additionally, the petitioner seeks an exemption from the requirements of Section 

91.151(b), entitled Fuel requirements for flight in VFR conditions. The petitioner 

submits that safety will not be affected by operation of the DJI Inspire 1 Professional 

UAs during daylight hours in visual meteorological conditions (VMC) under visual 

flight rules (VFR), with enough battery power to fly for a total duration of 

approximately 12 minutes to the first point of intended landing and, assuming normal 

cruising speed, to fly after that for at least 5 minutes.

In accordance with 14 C.F.R. § 11.81, the petitioner provides the following 

information in support of its petition for exemption:

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A. Name And Address Of The Petitioner.

The name and address of the Petitioner and point of contact is:

Over SF LLC

999 Green St. 

Suite #1101 

San Francisco, CA 94133 

Email:MailOverSF@gmail.com

B. The Specific Sections Of 14 C.F.R. From Which Over SF LLC Seeks Exemption.

1. The petitioner 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. Over SF LLC Seeks Exemption From The Requirements Of

Section 91.7(a).

Section 91.7, entitled Civil aircraft airworthiness, subsection (a), states the following:

(a) No person may operate a civil aircraft unless it is in an airworthy condition.

3. The petitioner Seeks Exemption From The Requirements Of Section

91.121.

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

part:

Page 7 of 31
(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.

4. The petitioner 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. The petitioner 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. The petitioner 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:

Page 8 of 31
(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. The petitioner 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.

8. The petitioner 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:

Page 9 of 31
(i) The total time in service of the airframe, each engine, each propeller, and 

each rotor.

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

propeller, rotor, and appliance.

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

are required to be overhauled on a specified time basis.

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

last inspection required by the inspection program under which the 

aircraft and its appliances are maintained.

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

directives including, for each, the method of compliance, the AD or 

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

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

required.

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

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

propellers, and appliances.

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

prescribed:

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

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

the work is performed.

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

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

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

this chapter shall be retained until the defects are repaired and the aircraft is 

approved for return to service.

C. The Extent Of Relief the petitioner Seeks And The Reason the petitioner 

Seeks The Relief. 

1. Extent Of Relief the petitioner Seeks And the petitioner Seeks Relief From 

Section 61.113(a) And (b).

Page 10 of 31
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 not 

holding any pilot certificate, or a current and valid airman medical certificate, but 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, The Petitioner submits that an equivalent level of 

safety will be maintained because no PIC will be allowed to operate the DJI Inspire 1 

Professional UAS unless that PIC has met certain flight-hour and currency requirements, 

demonstrating that the PIC is able to safely operate the DJI Inspire 1 Professional in a 

manner consistent with the operations specifications as described in this exemption, 

including evasive and emergency maneuvers, as well as maintaining appropriate distances 

from people, vessels, vehicles and structures.

 Further, Over SF LLC submits that all flights of the DJI Inspire 1

Professional UASs, conducted by the PIC pursuant to the grant of this Petition: (1) will be 

incidental to The Petitioner's business; and (2) will not carry passengers or property for

compensation or hire. 

2. Extent Of Relief the petitioner Seeks And The Reason the petitioner 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 the petitioner to determine that the DJI Inspire 1

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

UAS is in compliance with the operating documents (i.e., DJI Inspire 1 Professional 

Instruction Manual and Monthly Maintenance Log). 

The petitioner seeks the requested relief because the DJI Inspire 1

Professional UASs do not require an airworthiness certificate in accordance with 14 C.F.R. 

Part 21, Subpart H. Therefore, the petitioner will ensure that the DJI Inspire 1

Professional UASs are in airworthy condition based upon its compliance with the 

operating documents (i.e., Monthly Maintenance Log, and Inspire 1 Professional 

Instruction Manual) prior to every flight, and further, determine that the aircraft are in 

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

3. Extent Of Relief the petitioner, Seeks From Section 91.121.

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

flight operations of the DJI Inspire 1 Professional UASs, which utilize a barometric 

pressure sensor, GPS equipment, and a radio communications telemetry data link to 

downlink altitude information from the UA to the PIC at the ground control station

Page 11 of 31
(GCS). Since the FAA requires that any altitude information concerning UAS operations 

be reported to air traffic control (ATC) in feet above ground level (AGL), the petitioner 

seeks the requested relief because the DJI Inspire 1 Professional UA’s altimeter may be

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

altitude, before each flight.

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

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

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

be maintained since the DJI Inspire 1 Professional UAs are equipped with a barometric 

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

pressure setting will be established prior to each flight, and provides the PIC with altitude 

information of the UA on the heads-up display of the GCS.

4. Extent Of the petitioner Seeks And The Reason the petitioner Seeks Relief 

From Section 91.151(b).

Relief from Section 91.151(b) entitled Fuel requirements for flight in VFR 

conditions, is requested to the extent required to allow flights of the battery powered DJI 

Inspire 1 Professional UAs 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. The petitioner seeks the requested relief because without an exemption from 

Section 91.151(b), the flight time duration of the battery powered DJI Inspire 1

Professional UAs will severely constrain the practicality of any aerial video or still photo 

flight operations that the petitioner proposes to conduct pursuant to this Petition.

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

Professional UASs, the DJI Inspire 1 Professional operating documents, and the 

petitioner’s proposed operating limitations, ensure that the petitioner will safely operate 

the battery powered DJI Inspire 1 Professional UAs during daylight hours in visual 

meteorological conditions (VMC), under visual flight rules (VFR), with enough battery

power to fly for a total duration of 12 minutes to the first point of intended landing and,

assuming normal cruising speed, to fly after that for at least 5 minutes. 

5. Extent Of Relief the petitioner Seeks And The Reason the petitioner 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, the petitioner requests relief 

from these Sections because the DJI Inspire 1 Professional UASs do not require 

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

Professional UASs meet the conditions of FMRA Section 333 for operation without 

an airworthiness certificate. Accordingly, the petitioner will use trained technicians 

to perform maintenance, alterations, or preventive maintenance on the UASs using 

the methods, techniques, and practices prescribed in the UAS operating documents 

Page 12 of 31
(i.e., the DJI Inspire 1 Professional Instruction Manual and the Monthly

Maintenance Log). Furthermore, the petitioner will document and maintain all 

maintenance records for the DJI Inspire 1 Professional UASs. 

D. The Reasons Why Granting The Petitioner Request Would Be In The

Public Interest; That Is, How It Would Benefit The Public As A

Whole.

 Granting the this Petition will further the public interest by allowing Over SF LLC 

to operate their UAS in a safe and efficient manner. Safety will be increased over 

recreational use by performing routine pre-flight inspections, following written checklist, 

registration of the aircraft, logged flight experience with this exact UAS, operating within 

the restrictions of the 333 exemption and following the manufacture’s operation manual,. 

Safety will also be increased by operating a 6.5 pound vehicle in the air with no passengers 

vs. for example the popular Robison R44 (Raven 1) carrying 29 gallons of fuel and 

weighing 2,400 pounds fully loaded with passengers. 

Secondly, use of the DJI Inspire 1 Professional UASs will reduce carbon emissions,

decrease congestion of the NAS and benefit the economy by providing a more 

economical solution to our clients. The potential to increase crop production for our 

agricultural customers, reduce cost for our real-estate clients and increase safety for 

the public by inspecting critical infrastructure in a timely manner. 

 Lastly, the benefits of The Petitioner's proposed operation of the DJI Inspire 1 

Professional UASs will significantly reduce noise when compared to larger full scale 

helicopters and aircraft performing similar photography and video operations. 

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

The DJI Inspire 1 Professional UAs are battery powered and serve as a safe, 

efficient, and economical alternative to the manned aircraft traditionally utilized to obtain 

aerial imagery. By reducing the amount of manned aircraft needed to perform aerial 

acquisitions, an exemption allowing the use of a DJI Inspire 1 Professional UAS would 

reduce the amount of manned aircraft in the NAS, reduce noise and air pollution, as well 

as increase the safety of life and property in the air and on the ground.

Furthermore, by reducing the number of manned aircraft operating in the NAS, 

congestion around airports caused by arriving and departing aircraft will be reduced. The 

DJI Inspire 1 Professional UAs do not require an airport to takeoff or land. Likewise, a 

reduction of manned aircraft conducting aerial video and photography missions would 

result in fewer aircraft that must be handled by air traffic control during the ground, 

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

Page 13 of 31
2. The Public Will Benefit From The Safety And Efficiency Of The DJI 

Inspire 1 Professional UASs.

Conducting aerial acquisitions with the DJI Inspire 1 Professional UASs, instead 

of manned aircraft, will greatly benefit the public by drastically reducing the levels of air 

and noise pollution generated during traditional aerial video and still photography flight 

operations using manned rotorcraft. By using battery power and electric motors, the DJI 

Inspire 1 Professional UASs produce no air pollution, and is the most environmentally 

conscious alternative to six cylinder internal combustion engine aircraft that are typically 

utilized for aerial video and photography. For example, the popular aerial platform 

(Robison R44 Raven 1) utilizes 14 gallons AvGas per hour. On the other hand, the DJI 

Inspire 1 Professional UAs uses none. 

While reducing the carbon footprint of aerial acquisitions, the DJI Inspire 1 

Professional UAs, also reduces noise pollution. The DJI Inspire 1 Professional UAs is 

significantly quieter (even at close proximity) when compared to full size rotorcraft. 

By using the DJI Inspire 1 Professional UASs to perform aerial acquisitions, the 

substantial risk to life and property in the air and on the ground, which is usually 

associated with traditional manned aircraft flight operations, will be substantially reduced 

or completely eliminated. First, will be no flight crew members located onboard the 

aircraft. Secondly, the DJI Inspire 1 Professional UAs (weighing 6.5 pounds and 17 

inches by 18 inches by 12 inches, and no fuel on board), has less physical potential for 

collateral damage to life and property on the ground, and in the air, compared to manned 

rotorcraft that typically conduct similar operations (Robison R44 Raven 1 weighs 2,400 

pounds, 33 foot wingspan, 30 feet in length and a fuel capacity of 29 gallons).

3. Performing Aerial Video and Photography Operations With The DJI 

Inspire 1 Professional UASs Will Benefit The Economy.

In addition to being safe and efficient, the DJI Inspire 1 Professional UASs are also 

an economical alternative to using manned aircraft to conduct similar aerial operations. As 

such, operation of the DJI Inspire 1 Professional UASs will allow United States based 

companies, like The Petitioner, to remain competitive and contribute to growth of the U.S. 

economy. Specifically, with the rising cost of aviation fuel and the Environmental 

Protection Agency (“EPA”) regulatory actions phasing out leaded aviation fuels, U.S. 

owned and operated companies must adopt new and alternative technology in order to 

remain competitive. Operating the battery powered DJI Inspire 1 Professional

UASs 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. As of January 2015, the Robison Helicopter Company 

estimates an operating cost of $216 per flight hour for the R44 Raven 1. The DJI Inspire 1 

Professional UASs can be operated for significantly less. This reduction in operating cost 

can be passed directly onto the client, thus increasing our client’s profits. 

Page 14 of 31
By operating the DJI Inspire 1 Professional UASs, companies such as The 

Petitioner, can remain competitive and profitable, and therefore, provide greater job 

stability to employees and contractors, which will ultimately contribute to growth of the 

U.S. economy. Improved financial performance of U.S. companies, through commercial 

use of the DJI Inspire 1 Professional UASs, 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.

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 The Petitioner Seeks Exemption.

1. Reasons Why The DJI Inspire 1 Professional UAs Meet The Conditions Of

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

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

with the unmanned aircraft and its operation, The Petitioner operation of the DJI Inspire 

1 Professional UASs meet the conditions of FMRA Section 333, and will not require an 

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

Section 333 provides authority for a UAS to operate without airworthiness 

certification and sets forth requirements for considering whether a UAS will create a 

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

Specifically, FMRA Section 333 states the following, in part:

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

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

Transportation shall determine if certain unmanned aircraft systems may 

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

and rule making 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).

Page 15 of 31
(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, The Petitioner submits that the DJI Inspire 1

Professional UASs can operate safely in the NAS pursuant to FMRA Section 333, as 

demonstrated by: (a) the characteristics of the DJI Inspire 1 Professional UASs; (b) the pilot 

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

a. The Specifications Of The DJI Inspire 1 Professional UASs

Demonstrate Its Safe Characteristics.

The DJI Inspire 1 Professional UASs do not create a hazard to users of the NAS 

or the public, or otherwise pose a threat to national security considering its size, weight, 

speed, and operational capability.

i. Technical Specifications Of The DJI Inspire 1 Professional

UASs.

The technical specifications of the DJI Inspire 1 Professional UASs are set forth 

by the DJI Inspire 1 Professional Specifications, attached hereto as Exhibit A.

ii. The DJI Inspire 1 Professional UASs Autonomous Flight And Navigation 

Modes Enable The UASs To Remain Within A Defined Operational Area.

The DJI Inspire 1 Professional UASs may be operated in both manual and fully 

autonomous flight modes. A complete description of the flight and navigational modes of 

the DJI Inspire 1 Professional UASs is provided on page 12 of the DJI Inspire 1 

Professional User Manual, attached hereto as Exhibit B.

 iii. The DJI Inspire 1 Professional UASs Are Designed For 

Automatic Return To Home Point Or Hover In The Event Of Loss Of The Control 

Link Or Navigation.

When the Control Link is lost, the DJI Inspire 1 Professional UAs will remain 

stationary, in flight, for 3 seconds or more. If, after 3 seconds, the DJI Inspire 1 

Professional UAs do not reacquire Control Link data from the GSC, the UAs will 

assume that the Control Link is lost and the UAs will return to the home position (i.e., 

failsafe mode) via GPS, and will descend to the takeoff position and shutdown. 

A complete description of the Failsafe Functions of the DJI Inspire 1 

Professional UAS are set forth at page 15 of the DJI Inspire 1 Professional User Manual, 

attached hereto as Exhibit B.

 iv. The DJI Inspire 1 Professional Remote Controller And Its Operation.

A complete description of the operation and specifications of the DJI Inspire 1

Page 16 of 31
Professional Remote Controller, GSC and flight control software is provided at pages 24 

through 33 of the DJI Inspire 1 Professional User Manual. DJI Inspire 1 Professional User 

Manual is attached hereto as Exhibit B.

b. Flight Operations Of DJI Inspire 1 Professional UASs Are Limited To

The Line Of Sight Of A Pilot in Command With A Safety Observer.

The Petitioner will only utilize pilots who have at least 20 hours flight time to act 

as a pilot in command (PIC) of the DJI Inspire 1 Professional UASs. Additionally, a 

safety observer will assist all pilots during flight time.

c. Flights Of DJI Inspire 1 Professional UASs Will Be Conducted

Pursuant To Specific Operating Limitations.

In seeking this exemption, The Petitioner proposes to commercially operate

DJI Inspire 1 Professional UASs for the special purpose of conducting aerial video 

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

specific operating limitations:

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

aircraft described in the operating documents, rotorcraft UASs weighing less

than 55 pounds maximum gross weight: DJI Inspire 1 Professional Unmanned 

Aircraft Systems. Proposed operations of any other aircraft will require a new 

petition or a petition to amend this grant.

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

for the purpose of aerial video and photography.

3. The UAs may not be flown at an indicated airspeed exceeding 87 knots

 (100 miles per hour).

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 unless a special request is made and approved by ATC. All altitudes 

reported to ATC must be in feet AGL.

5. The UAs 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. All operations must utilize a safety observer (SO). The SO may be used to satisfy 

the VLOS requirement as long as the PIC always maintains VLOS capability. 

The SO and PIC must be able to communicate verbally at all times. Electronic 

messaging or texting is not permitted during flight operations. The PIC must be 

Page 17 of 31
designated before the flight and cannot transfer his or her designation for the 

duration of the flight. The PIC must ensure that the SO can perform the

functions prescribed in the operating documents.

7. The SO must not perform any other duties beyond assisting the PIC with seeing 

and avoiding other air traffic and other ground based obstacles/obstructions and 

is not permitted to operate the camera or other instruments.

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

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

discrepancy exists between the conditions and limitations contained in the grant 

of exemption and the procedures outlined in the operating documents, the 

conditions and limitations contained in the grant of exemption take precedence 

and must be followed. Otherwise, the operator must follow the procedures as 

outlined in its operating documents. The operator may update or revise its 

operating documents. It is the operator’s responsibility to track such revisions 

and present updated and revised documents to the Administrator upon request. 

The operator must also present updated and revised documents if it petitions for 

extension or amendment to the grant of exemption. If the operator determines 

that any update or revision would affect the basis upon which the FAA granted 

the exemption, then the operator must petition for amendment to its grant of 

exemption. The FAA’s UAS Integration Office (AFS-80) may be contacted if 

questions arise regarding updates or revisions to the operating documents.

9. Prior to each flight the PIC must inspect the UAS to ensure that it is in a 

condition for safe flight. If the inspection reveals a condition that affects the 

safe operation of the UAS, the aircraft is prohibited from operating until the 

necessary maintenance has been performed and the UAS is found to be in a 

condition for safe flight. The GSC must be included in the preflight 

inspection. All maintenance and alterations must be properly documented in 

the aircraft records.

10. 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.

11. 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.

12. The operator must follow the UAS manufacturer’s aircraft/component, 

maintenance, overhaul, replacement, inspection, and life limit 

requirements.

Page 18 of 31
13. 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.

14. Each UASs operated under this exemption must comply with all manufacturer

Safety Bulletins.

15. The authorized person must make an entry in the aircraft record of the 

corrective action taken against discrepancies discovered between inspections.

16. The PIC must have completed at least 25 hours of flight time.

17. The operator may not permit any PIC to operate unless the PIC meets the 

operator’s qualification criteria and demonstrates the ability to safely operate 

the UAS in a manner consistent with how the UAS will be operated under the 

exemption, including evasive and emergency maneuvers and maintaining 

appropriate distances from persons, vessels, vehicles and structures. PIC 

qualification flight hours must be logged in a manner consistent with 14 C.F.R.

§ 61.51(b). Flights for the purposes of training the operator’s PICs are 

permitted under the terms of the exemption. However, training operations may 

only be conducted during dedicated training sessions. During training, 

proficiency, and experience-building flights, all persons not essential for flight 

operations are considered nonparticipants, and the PIC must operate the UA 

with appropriate distance from nonparticipants in accordance with 14 C.F.R. §

91.119.

18. UAS operations may not be conducted during night, as defined in 14 C.F.R. §

1.1. All operations must be conducted under visual meteorological conditions 

(VMC). If flight at night is required, a special request will be made at the FAA 

office closest to proposed area of operations. Flights under special visual flight 

rules (SVFR) are not authorized.

19. The UA may not operate within 2 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.

20. The UA may not be operated less than 400 feet below or less than 2,000 feet 

horizontally from a cloud or when visibility is less than 3 statute miles from the 

PIC.

Page 19 of 31
21. 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.

22. The PIC must abort the flight in the event of unpredicted obstacles or 

emergencies in accordance with the operating documents.

23. 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.

24. The operator must obtain an Air Traffic Organization (ATO) issued Certificate 

of Waiver or Authorization (COA) prior to conducting any operations under the 

grant of exemption. This COA will also require the operator to request a Notice 

to Airman (NOTAM) not more than 72 hours in advance, but not less than 48 

hours prior to the operation. All operations shall be conducted in accordance 

with airspace requirements in the ATO issued COA including class of airspace, 

altitude level and potential transponder requirements.

25. 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 (N- Number) markings in accordance with 14 C.F.R. part 45, 

Subpart C. Markings must be as large as practicable.

26. 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.

27. The documents required fewer than 14 C.F.R. 91.9 and 91.203 must be 

available to the PIC at the Ground Control Station of the UAS any time the 

UAS is operating. These documents must be made available to the 

Administrator or any law enforcement official upon request.

28. The UA must remain clear and yield the right of way to all manned aviation 

operations and activities at all times.

30. The UAS may not be operated by the PIC from any moving device or vehicle.

31. Flight operations must be conducted at least 500 feet from all nonparticipating 

persons (persons other than the PIC, SO, operator trainees or essential persons), 

vessels, vehicles, and structures unless:

Page 20 of 31
a. Barriers or structures are present that sufficiently protect nonparticipating 

persons from the UA and/or debris in the event of an accident. The 

operator must ensure that nonparticipating persons remain under such 

protection. If a situation arises where nonparticipating persons leave such 

protection and are within 500 feet of the UA, flight operations must cease 

immediately and/or;

b. The aircraft is operated near vessels, vehicles or structures where the 

owner/controller of such vessels, vehicles or structures has granted 

permission and the PIC has made a safety assessment of the risk of 

operating closer to those objects and determined that it does not present 

an undue hazard, and;

c. Operations nearer to the PIC, SO, operator trainees or essential persons 

do not present an undue hazard to those persons per § 91.119(a).

32. All operations shall be conducted over private or controlled-access property 

with permission from the land owner/controller or authorized representative. 

Permission from land owner/controller or authorized representative will be 

obtained for each flight to be conducted.

33. Any incident, accident, or flight operation that transgresses the lateral or 

vertical boundaries of the operational area as defined by the applicable COA 

must be reported to the FAA's UAS Integration Office (AFS-80) within 24 

hours. Accidents must be reported to the National Transportation Safety Board 

(NTSB) per instructions contained on the NTSB Web site: www.ntsb.gov.

2. Reasons Why An Exemption From The Requirements Of Section 61.113(a) 

And (b) Would Not Adversely Affect Safety.

The Petitioner submits that the equivalent level of safety established by Section 

61.113(a) and (b) will be maintained because no PIC will be allowed to operate the DJI 

Inspire 1 Professional UASs unless that PIC has demonstrated, by meeting minimum 

flight-hour and currency requirements, that the PIC is able to safely operate the DJI 

Inspire 1 Professional UAS in a manner consistent with the exemption, including 

evasive and emergency maneuvers and maintaining appropriate distances from people, 

vessels, vehicles and structures.

Considering The Petitioner's proposed area of operations, and the operating 

limitations set forth-above; the parallel nature of aeronautical knowledge

Page 21 of 31
requirements to those of commercial pilot requirements (See Exemption No. 11062); and 

the airmanship skills necessary to safely operate the DJI Inspire 1 Professional, The 

Petitioner submits that the additional manned airmanship experience of a commercially 

certificated pilot would not correlate to the airmanship skills necessary for The 

Petitioner's specific proposed flight operations.

The FAA has previously granted relief from Section 61.113(a) and (b) specific to 

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

Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112,

11136, 11138, 11150, 11153, 11156, 11158, 11159, 11160, 11161).

The Petitioner will not allow any PIC to operate the DJI Inspire 1

Professional UAS unless that PIC has demonstrated, by meeting minimum flight-hour 

requirements or the DJI Inspire 1 Professional UAS training and currency requirements, 

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

consistent with this exemption, including evasive and emergency maneuvers and 

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

Specifically, the PIC must have accumulated and logged, in a manner consistent 

with 14 C.F.R. § 61.51(b), 25 hours of total time as a UAS rotorcraft pilot (with a 

minimum of 5 hours of those hours as a UAS pilot operating the same make and model of 

UAS to be used for operations under the exemption). In addition to the hour requirements, 

the PIC must accomplish 3 takeoffs and landings in the preceding 90 days (for currency 

purposes).

As in Exemption Nos. 11062, 11138, and 11153, prior documented flight 

experience that was obtained in compliance with applicable regulations will ensure an 

equivalent level of safety during The Petitioner's proposed operations. The Administrator 

has held that prior documented flight experience that was obtained in compliance with 

applicable regulations would ensure safe operations, stating as follows:

In Exemption No. 11062, the FAA required that prior to conducting operations for 

the purpose of motion picture filming (or similar operations), the PIC must have 

accumulated and logged, in a manner consistent with 14 CFR 61.51(b), 25 hours of 

total time as a UAS rotorcraft pilot including at least 10 hours logged as a UAS 

pilot with a multi-rotor UAS. Prior to operations under Exemption No. 11062, the 

PIC must also have accumulated and logged a minimum of 5 hours as a UAS pilot 

operating the same make and model of UAS to be used for operations under the 

exemption. For clarification, the FAA considers these minimum hour requirements 

to be inclusive rather than additive; i.e. 5 hours make and model time may be 

included in the 10 hours of multi-rotor time and the 10 hours may be included in

the total 25 hours of UAS rotorcraft time. In addition to the hour requirements, the

PIC must accomplish 3 takeoffs and landings in the preceding 90 days (for

currency purposes). The FAA finds that at a minimum, the flight-hour requirements 

in Exemption No. 11062 are appropriate to practice and build proficiency in the 

skills necessary to safely conduct the petitioner’s proposed operations. The FAA 

also finds that prior documented flight experience that was obtained in compliance 

with applicable regulations would satisfy this requirement. Training, proficiency, 

Page 22 of 31
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, The Petitioner will ensure safe operations by not allowing any PIC

to operate the DJI Inspire 1 Professional UAS unless that PIC has demonstrated, by meeting 

minimum flight-hour and currency requirements, that the PIC is able to safely operate the DJI 

Inspire 1 Professional UAS in a manner consistent with the exemption, including evasive and 

emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles 

and structures.

 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, The Petitioner will ensure that the DJI Inspire 1

Professional UAS is in an airworthy condition based upon the UAS’s compliance with its 

operating documents and as stated in the conditions and limitations herein. Additionally, 

the FAA has previously granted relief from Section 91.7(a) specific to UAS, in 

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

Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112, 11136,

11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161).

4. Reasons Why An Exemption From The Requirements Of Section 91.121

Would Not Adversely Affect Safety.

The equivalent level of safety established by Section 91.121 will be maintained 

because the altitude information of the DJI Inspire 1 Professional UAs will be provided 

to the PIC via GPS equipment and a radio communications telemetry data link, which 

downlinks from the UA to the GCS for active monitoring of the flight path and altitude. 

This altitude information, combined with The Petitioner's operation of the DJI Inspire 1 

Professional UAs within visual line of sight, at or below 400 feet AGL, will ensure a 

level of safety equivalent to Section 91.121. The altitude information will be generated 

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

initiation point is automatically established by the UASs at ground level.

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

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

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

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

5. Reasons Why An Exemption From The Requirements Of Section 

91.151(b) Would Not Adversely Affect Safety.

A grant of this exemption would ensure an equivalent level of safety established by

Page 23 of 31
14 C.F.R. Section 91.151(b) as a result of (1) the technical specifications of the DJI 

Inspire 1 Professional UASs; (2) the limitations on the proposed flight operations; and 

(3) the location of the proposed flight operations. Accordingly, The Petitioner will 

ensure that it will safely operate the battery powered DJI Inspire 1 Professional UAs 

during daylight hours in VFR conditions, with enough battery power to fly for a total 

duration of 12 minutes to the first point of intended landing and, assuming normal 

cruising speed, to fly after that for at least 5 minutes. 

Here, as in Exemption No. 11109, the technical specifications of the DJI Inspire 1 

Professional UASs; the limitations on the proposed flight operations; and the location of 

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

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

UASs provide audible and visual warnings to the PIC at the GCS when the UAs 

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

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

critically low battery level, the DJI Inspire 1 Professional UASs will descend and land 

automatically.

Significantly, previous exemptions granted by the FAA concerning Section 91.151 

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

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

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

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

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

those presented herein (e.g. Exemption Nos. 8811, 10808, 10673, 11042, 11062, 11063,

11064, 11065, 11066, 11067, 11080, 11109, 11110, 11136, 11138, 11150, 11153, 11156,

11157, 11158, 11159, 11160, 11161).

6. Reasons Why An Exemption From The Requirements Of Sections

91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), And 91.417(a) & (b) Would

Not Adversely Affect Safety.

In seeking this exemption, The Petitioner 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 The Petitioner will use trained technicians to perform maintenance, 

alterations, or preventive maintenance on the UASs using the methods, techniques, and 

practices prescribed in the operating documents (i.e., the DJI Inspire 1 Professional 

Instruction Manual, Monthly Maintenance Log). Furthermore, The Petitioner will 

document and maintain all maintenance records for the DJI Inspire 1 Professional 

UASs.

Since the DJI Inspire 1 Professional UASs will be inspected as prescribed by the 

operating documents, The Petitioner will maintain the equivalent level of safety 

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

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

Inspire 1 Professional UAS Maintenance LOG is attached hereto as Exhibit C.

Page 24 of 31
Likewise, the exemption sought will not adversely affect safety because The 

Petitioner will use trained technicians to perform maintenance, alterations or 

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

prescribed by the operating documents.

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

established by Sections 91.407, 91.417(a) and 91.417(b), because all maintenance of the 

DJI Inspire 1 Professional UASs will be performed by trained technicians. Maintenance 

will be documented and maintained utilizing the monthly maintenance log.

Significantly, previous exemptions granted by the FAA concerning Sections

91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) establish that safety is 

not adversely affected when the technical characteristics and operating limitations of the 

UAS are considered.

In consideration of The Petitioner's proposed operating limitations, the operating 

documents, and the technical aspects of the DJI Inspire 1 Professional UASs, The 

Petitioner submits that safety will not be adversely affected by granting exemption from 

14 C.F.R. Sections 91.405(a), 91.407(a)(1) and (a)(2), 91.409(a)(2), and

91.417(a) and (b). The FAA has previously granted relief specific to UAS in circumstances 

similar, in all material respects, to those presented herein (e.g. Exemption Nos. 11062,

11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112, 11136, 11138, 11150,

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

7. The FAA May Prescribe Any Other Conditions For Safe Operation.

In accordance with Section 333 of the FAA Modernization and Reform Act of 2012 

(FMRA) and 14 C.F.R. § 21.16 entitled Special Conditions, The Petitioner requests that the 

FAA prescribe special conditions for the intended operation of the DJI Inspire 1

Professional UASs, 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 UAs for the limited purpose of 

conducting aerial video and photography over certain areas of the United States for 

compensation or hire. FMRA Section 333 sets forth the requirements for considering 

whether a UAS will create a hazard to users of the NAS or the public, or otherwise pose a 

threat to national security; and further, provides the authority for such UAS to operate 

without airworthiness certification in accordance with any requirements that must be 

established for the safe operation of the UAS in the NAS.

Likewise, the Administrator may prescribe special conditions pursuant to 14 C.F.R.

§ 21.16, for operation of the DJI Inspire 1 Professional UASs, since the airworthiness 

regulations of 14 C.F.R. Part 21 do not contain adequate or appropriate safety standards, 

due to the novel or unusual design features of the aircraft. Section 21.16, entitled Special 

Conditions, states the following:

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 

Page 25 of 31
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 The Petitioner’s intended operation of the DJI Inspire 

1 Professional UASs, 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 The Petitioner Seeks Exemption:

The Petitioner 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 The Petitioner Seeks:

This exemption will permit The Petitioner to commercially operate an Unmanned 

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

photography over certain areas of the United States.

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

The Petitioner'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, The Petitioner's request for exemption may

be granted pursuant to the authority of FMRA Section 333 and 14 C.F.R. Part 11, as set 

forth above.

FMRA Section 333 sets forth the requirements for considering whether a UAS will 

create a hazard to users of the NAS or the public, or otherwise pose a threat to national 

security; and further, provides the authority for such UAS to operate without airworthiness 

certification.

As discussed in detail above, The Petitioner will operate the DJI 

Inspire 1 Professional UASs safely in the NAS, without creating a hazard to 

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

Page 26 of 31
CONCLUSION

As set forth herein, The Petitioner 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 DJI Inspire 1 Professional UASs 

commercially, without an airworthiness certificate, for the limited purpose of 

conducting aerial video and photography over certain areas of the United States. By 

granting this Petition, the FAA Administrator will be fulfilling the Congressional 

mandate of the FAA Modernization and Reform Act of 2012, while also advancing the 

interests of the public, by allowing The Petitioner to safely, efficiently, and 

economically operate the DJI Inspire 1 Professional UASs commercially within the 

NAS.

WHEREFORE, in accordance with the Federal Aviation Regulations and the FAA 

Modernization and Reform Act of 2012, Section 333, The Petitioner 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 The Petitioner to operate the DJI 

Inspire 1 Professional UASs commercially for the purpose of conducting aerial video and 

photography over certain areas of the United States.

Dated: August 23, 2015

Respectfully submitted,

The Petitioner

Over SF LLC

999 Green St. 

Suite#1101 

San Francisco, CA 94133 

MailOverSF@gmail.com

Page 27 of 31
Appendices:

A – DJI Inspire 1 Professional Specifications Data Sheet

B – DJI Inspire 1 Professional Manufacturer’s User Manual

C – Monthly Maintenance Log

Page 28 of 31
APPENDIX – A

DJI Inspire 1 Professional TECHNICAL SPECIFICATIONS

The Petitioner only utilizes safe and reliable UASs. DJI is an industry leader in small UAS 

production. DJI UASs are loaded with ground breaking software enabling the user to set 

parameters which will not allow flight into controlled airspace. Parameters can also be set 

to limit flight to no higher than a predetermined and set altitude as well as limit flight to a 

predetermined and set distance. In addition, DJI software provides real-time altitude and 

location information to the PIC via the linked monitor (smart phone/tablet devices)

1.1 DJI Inspire 1 Professional

1.1.1 Aircraft

1.1.1.1 Supported Battery – DJI 5700mAH LiPo Battery

1.1.1.2 Weight (Battery & Propellers Included) – 6.5lbs. 2935g

1.1.1.3 Hover Accuracy (Ready to Fly) – Vertical: 0.5m; Horizontal: 2.5m

1.1.1.4 Max Flight time - Approximately 18 minutes

1.1.1.5 Max Tilt Angel - 350

1.1.1.6 Max Ascent Speed – 5m/s

1.1.1.7 Max Descent Speed – 4m/s

1.1.1.8 Max Flight Speed – 22m/s (ATTI mode, no wind)

1.1.1.9 Operating Temperature - 10oC - 40oC

1.1.1.10 Max Flight Altitude - 4500m

1.1.1.11 GPS Mode - GPS

1.1.2 Gimbal

1.1.2.1 Controllable Range – Pitch: -900 +300

1.1.3 Camera

1.1.3.1 Sensor - Sony EXMOR 1/2.3"

1.1.3.2 Lens - 20mm (35mm format equivalent) 

1.1.3.3 Effective Pixels – 12.4M

1.1.3.4 Resolution – 4000x3000

4.1.3.5 HD Video Recording – 4K, 1080p & 720p

4.1.3.6 Image Max Size - 4000 x 3000

1.1.4 Remote Controller

1.1.4.1 Operating Frequency – 5.725~5.825 GHz;2.400~2.483 GHz

1.1.4.2 Communication Distance (unobstructed) - 2km

1.1.4.3 Battery - 6000 mAh LiPo 2s

1.1.4.4 Transmitter Power – FCC: 9w

1.1.4.5 Working Voltage – 1.2 A @7.4 V

Page 29 of 31
APPENDIX – B

DJI Inspire 1 Professional Manufacturer’s User Manual

can be found at: 

http://download.dji-innovations.com/downloads/

inspire_1/en/

Inspire_1_User_Manual_v1.4_en.pdf

Page 30 of 31
APPENDIX – C

Page 31 of 31