June 25, 2015

Exemption No. 11910

Regulatory Docket No. FAA–2015–1333

Mr. Thomas Goodall

210 Via Nada

San Clemente, CA 92672

Dear Mr. Goodall:

This letter is to inform you that we have granted your request for exemption. It transmits our 

decision, explains its basis, and gives you the conditions and limitations of the exemption, 

including the date it ends.

By letter posted April 29, 2015, you petitioned the Federal Aviation Administration (FAA) for 

an exemption. The petitioner requested to operate an unmanned aircraft system (UAS) to 

conduct aerial cinematography and photography of golf courses, special events, and real 

estate.

See Appendix A for the petition submitted to the FAA describing the proposed operations and 

the regulations that the petitioner seeks an exemption.

The FAA has determined 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.

Airworthiness Certification

The UAS proposed by the petitioner is the DJI Inspire 1.

The petitioner requested relief from 14 CFR part 21, Certification procedures for products 

and parts, Subpart H—Airworthiness Certificates. In accordance with the statutory criteria 
2

provided in Section 333 of Public Law 112−95 in reference to 49 U.S.C. § 44704, and in 

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

aircraft and its operation, the Secretary of Transportation has determined that this aircraft 

meets the conditions of Section 333. Therefore, the FAA finds that the requested relief from 

14 CFR part 21, Certification procedures for products and parts, Subpart H—Airworthiness 

Certificates, and any associated noise certification and testing requirements of part 36, is 

not necessary.

The Basis for Our Decision

You have requested to use a UAS for aerial data collection1. The FAA has issued grants of 

exemption in circumstances similar in all material respects to those presented in your 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), and 11213 to Aeryon Labs, Inc. (see Docket No. 

FAA−2014−0642), 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 significantly greater proportions, carrying crew in 

addition to flammable fuel, gives the FAA good cause to find that the UAS operation enabled 

by this exemption is in the public interest.

Having reviewed your reasons for requesting an exemption, I find that—

• They are similar in all material respects to relief previously requested in Grant of 

Exemption Nos. 11062, 11109, 11112, and 11213;

• The reasons stated by the FAA for granting Exemption Nos. 11062, 11109, 11112, and 

11213 also apply to the situation you present; and 

• A grant of exemption is in the public interest.

Our Decision

In consideration of the foregoing, I find that a grant of exemption is in the public interest. 

Therefore, pursuant to the authority contained in 49 U.S.C. 106(f), 40113, and 44701, 

delegated to me by the Administrator, Thomas Goodall is granted an exemption from 14 CFR 

§§ 61.23(a) and (c), 61.101(e)(4) and (5), 61.113(a), 61.315(a), 91.7(a), 91.119(c), 91.121, 

91.151(a)(1), 91.405(a), 91.407(a)(1), 91.409(a)(1) and (2), and 91.417(a) and (b), to the 

extent necessary to allow the petitioner to operate a UAS to perform aerial data collection. 

This exemption is subject to the conditions and limitations listed below.

 

1 Aerial data collection includes any remote sensing and measuring by an instrument(s) aboard the UA. 

Examples include imagery (photography, video, infrared, etc.), electronic measurement (precision surveying, RF 

analysis, etc.), chemical measurement (particulate measurement, etc.), or any other gathering of data by 

instruments aboard the UA.
3

Conditions and Limitations

In this grant of exemption, Thomas Goodall is hereafter referred to as the operator.

Failure to comply with any of the conditions and limitations of this grant of exemption will be 

grounds for the immediate suspension or rescission of this exemption.

1. Operations authorized by this grant of exemption are limited to the DJI Inspire 1 when 

weighing less than 55 pounds including payload. Proposed operations of any other 

aircraft will require a new petition or a petition to amend this exemption.

2. Operations for the purpose of closed-set motion picture and television filming are 

not permitted. 

3. The UA may not be operated at a speed exceeding 87 knots (100 miles per hour). The 

exemption holder may use either groundspeed or calibrated airspeed to determine 

compliance with the 87 knot speed restriction. In no case will the UA be operated at 

airspeeds greater than the maximum UA operating airspeed recommended by the 

aircraft manufacturer.

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

(AGL). Altitude must be reported in feet AGL.

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

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

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

U.S. driver’s license.

6. All operations must utilize a visual observer (VO). The UA must be operated within 

the visual line of sight (VLOS) of the PIC and VO at all times. The VO may be used 

to satisfy the VLOS requirement as long as the PIC always maintains VLOS 

capability. The VO and PIC must be able to communicate verbally at all times; 

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

must be designated before the flight and cannot transfer his or her designation for the 

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

required of the VO.

7. This exemption and all documents needed to operate the UAS and conduct its 

operations in accordance with the conditions and limitations stated in this grant of 

exemption, are hereinafter referred to as the operating documents. The operating 

documents must be accessible during UAS operations and made available to the 

Administrator upon request. If a discrepancy exists between the conditions and 

limitations in this exemption and the procedures outlined in the operating documents,

the conditions and limitations herein take precedence and must be followed. 
4

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 or any law enforcement official upon request. The 

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

or amendment to this grant of exemption. If the operator determines that any update 

or revision would affect the basis upon which the FAA granted this exemption, then 

the operator must petition for an 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.

8. 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 prior to conducting further operations under this exemption. 

Functional test flights may only be conducted by a PIC with a VO and must remain at 

least 500 feet from other people. The functional test flight must be conducted in such 

a manner so as to not pose an undue hazard to persons and property.

9. The operator is responsible for maintaining and inspecting the UAS to ensure that it is 

in a condition for safe operation.

10. Prior to each flight, the PIC must conduct a pre-flight inspection and determine the 

UAS is in a condition for safe flight. The pre-flight inspection must account for all 

potential discrepancies, e.g., inoperable components, items, or equipment. 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.

11. The operator must follow the UAS manufacturer’s maintenance, overhaul, 

replacement, inspection, and life limit requirements for the aircraft and 

aircraft components.

12. Each UAS operated under this exemption must comply with all manufacturer 

safety bulletins.

13. Under this grant of exemption, a PIC must hold either an airline transport, 

commercial, private, recreational, or sport pilot certificate. The PIC must also hold a 

current FAA airman medical certificate or a valid U.S. driver’s license issued by a 

state, the District of Columbia, Puerto Rico, a territory, a possession, or the Federal 

government. The PIC must also meet the flight review requirements specified in 

14 CFR § 61.56 in an aircraft in which the PIC is rated on his or her pilot certificate.

14. The operator may not permit any PIC to operate unless the PIC demonstrates the 

ability to safely operate the UAS in a manner consistent with how the UAS will be 
5

operated under this exemption, including evasive and emergency maneuvers and 

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

qualification flight hours and currency must be logged in a manner consistent with 

14 CFR § 61.51(b). Flights for the purposes of training the operator’s PICs and VOs 

(training, proficiency, and experience-building) and determining the PIC’s ability to 

safely operate the UAS in a manner consistent with how the UAS will be operated 

under this exemption are permitted under the terms of this 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 CFR § 91.119.

15. UAS operations may not be conducted during night, as defined in 14 CFR § 1.1. All 

operations must be conducted under visual meteorological conditions (VMC). Flights 

under special visual flight rules (SVFR) are not authorized.

16. The UA may not operate within 5 nautical miles of an airport reference point (ARP) as 

denoted in the current FAA Airport/Facility Directory (AFD) or for airports not 

denoted with an ARP, the center of the airport symbol as denoted on the current 

FAA-published aeronautical chart, unless a letter of agreement with that airport’s 

management is obtained or otherwise permitted by a COA issued to the exemption 

holder. The letter of agreement with the airport management must be made available 

to the Administrator or any law enforcement official upon request.

17. The UA may not be operated less than 500 feet below or less than 2,000 feet 

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

18. If the UAS loses communications or loses its GPS signal, the UA must return to a

pre-determined location within the private or controlled-access property.

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

20. The PIC is prohibited from beginning a flight unless (considering wind and forecast 

weather conditions) there is enough available power for the UA to conduct the 

intended operation and to operate after that for at least five minutes or with the reserve 

power recommended by the manufacturer if greater.

21. Air Traffic Organization (ATO) Certificate of Waiver or Authorization (COA). All 

operations shall be conducted in accordance with an ATO-issued COA. The 

exemption holder may apply for a new or amended COA if it intends to conduct 

operations that cannot be conducted under the terms of the attached COA.

22. All aircraft operated in accordance with this exemption must be identified by serial 

number, registered in accordance with 14 CFR part 47, and have identification 
6

(N−Number) markings in accordance with 14 CFR part 45, Subpart C. Markings must 

be as large as practicable.

23. Documents used by the operator to ensure the safe operation and flight of the UAS and 

any documents required under 14 CFR §§ 91.9 and 91.203 must be available to the 

PIC at the Ground Control Station of the UAS any time the aircraft is operating. 

These documents must be made available to the Administrator or any law enforcement 

official upon request.

24. The UA must remain clear and give way to all manned aviation operations and 

activities at all times. 

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

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

persons, vessels, vehicles, and structures unless:

a. Barriers or structures are present that sufficiently protect nonparticipating persons 

from the UA and/or debris in the event of an accident. The operator must ensure 

that nonparticipating persons remain under such protection. If a situation arises 

where nonparticipating persons leave such protection and are within 500 feet of 

the UA, flight operations must cease immediately in a manner ensuring the safety 

of nonparticipating persons; and

b. The owner/controller of any vessels, vehicles or structures has granted permission 

for operating closer to those objects 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.

The PIC, VO, operator trainees or essential persons are not considered 

nonparticipating persons under this exemption.

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

permission from the property owner/controller or authorized representative. 

Permission from property owner/controller or authorized representative will be 

obtained for each flight to be conducted.

28. 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.

If this exemption permits operations for the purpose of closed-set motion picture and 

television filming and production, the following additional conditions and limitations apply.
7

29. The operator must have a motion picture and television operations manual (MPTOM) 

as documented in this grant of exemption.

30. At least 3 days before aerial filming, the operator of the UAS affected by this 

exemption must submit a written Plan of Activities to the local Flight Standards 

District Office (FSDO) with jurisdiction over the area of proposed filming. The 3-day 

notification may be waived with the concurrence of the FSDO. The plan of activities 

must include at least the following:

a. Dates and times for all flights;

b. Name and phone number of the operator for the UAS aerial filming conducted 

under this grant of exemption;

c. Name and phone number of the person responsible for the on-scene operation of 

the UAS;

d. Make, model, and serial or N−Number of UAS to be used;

e. Name and certificate number of UAS PICs involved in the aerial filming;

f. A statement that the operator has obtained permission from property owners

and/or local officials to conduct the filming production event; the list of those 

who gave permission must be made available to the inspector upon request;

g. Signature of exemption holder or representative; and

h. A description of the flight activity, including maps or diagrams of any area, city, 

town, county, and/or state over which filming will be conducted and the altitudes 

essential to accomplish the operation.

31. Flight operations may be conducted closer than 500 feet from participating persons 

consenting to be involved and necessary for the filming production, as specified in the 

exemption holder’s MPTOM.

Unless otherwise specified in this grant of exemption, the UAS, the UAS PIC, and the UAS 

operations must comply with all applicable parts of 14 CFR including, but not limited to, 

parts 45, 47, 61, and 91.
8

This exemption terminates on July 31, 2017, unless sooner superseded or rescinded.

Sincerely,

/s/

John S. Duncan

Director, Flight Standards Service

Enclosures
I, Thomas Goodall, have been flying UA's for 4 years, my most recent experience is with the Inspire 1 

built by DJI. I have been flying as a Hobbyist and now ready to bring my skills to a professional level for 

three reasons; Cinematography for Golf Courses, Special Events and Real Estate. In doing so I consider 

all safety precautions and regulations as foremost with each flight.

I seek exception from 14 C.F.R. 21, subpart H; 14 C.F.R. 45.23(b); 14 C.F.R. §§ 61.113 (a) & 

(b); 14 C.F.R. § 91.7 (a); 14 C.F.R. § 91.9 (b)(2); 14 C.F.R. § 91.103(b); 14 C.F.R. § 91.109; 14 

C.F.R. § 91.119; 14 C.F.R. § 91.121; 14 C.F.R. § 91.151(a); 14 C.F.R. §§ 91.203(a) and (b); 14 

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

(2); and, 14 C.F.R. §§ 91.417 (a) & (b) to commercially operate.

Golf Course Cinematography: 

I, Thomas Goodall, considers safety and regulations as foremost with each flight. My small unmanned 

aircraft is designed to hover in place via GPS and operate in less than a 24 knot (15 mph) wind. For safety, 

stability and fear of financial loss I will not fly in winds exceeding 16 kph (10 mph) nor will I fly my UA 

faster than 30 mph nor go over 200 feet from ground, far safer then the 400 foot limit. Built in safety 

systems include a GPS mode that allows my UAS to hover in place when radio controls are released. 

With three modes to choose from, I utilize the Smart Mode for aerial videography/photography. This is 

the safest, most reliable and stable mode to prevent accident and hazard. When pilot communication is 

lost the UAS is designed to slowly descend to point of take off. I do not operate my UAS near airports, 

Hospitals nor Police heliports, I am also prepared to land/abort immediately to the nearest and safest 

ground point that I have planned ahead of take off. 

Aerial footage of Golf Courses would help give the public a geographical awareness of the course before 

playing. It helps Golfers improve their game when they have the ability to map out landing zones. Also 

using my UA avoids the high risks in the use of a helicopter with fuel and persons on board. 

After consent of the Golf Course I, Thomas Goodall operating the Dji Inspire 1, would first observe the 

flight area for any mobile phone base stations, radio transmission towers, power lines or any other 

electromagnetic interference that could disrupt flight. I would scan the area for any large buildings or 

trees that may affect with GPS accuracy or flight. I then would make sure the weather is flight ready to 

avoid wind speed exceeding 10m/s , snow, rain and smog also to be sure the UA and battery performance 

is subject to safe air density and temperature. For safety, stability and fear of financial loss I will not 

operate unless perfect conditions are present. I make sure I am in the 5 mile radius of any airports and to 

stay under 400 feet from ground. 

Next I would then coordinate a safe fly time where all Persons and property are in safe distance from my 

UA during take off and flight. Lastly I 

would go through my normal maintenance and pre-flight Checklist;

1. Remote controller, aircraft battery, and mobile device are fully charged. 
2. Propellers are mounted correctly and firmly.

 3. Micro-SD card has been inserted if necessary.

 4. Gimbal is functioning as normal.

 5. Motors can start and are functioning as normal. 6. 

DJI Pilot app connected to the aircraft. 

then following up with flight test procedures;

 1. Place the aircraft on open, flat ground with battery indicators facing towards me.

 2. Power on the remote controller and your mobile device, then the Intelligent Flight Battery.

 3. Launch the DJI Pilot App and enter the Camera page.

 4. Wait until the Aircraft Indicator blinks green. This means the Home Point is recorded via GPS

 5. calibrate the compass flight location.

 6. Push the throttle up slowly to take off 

 7. Shoot photos and videos using the DJI Pilot app.

 8. To land, hover over a level surface and gently pull down on the throttle slowly to descend.

 9. After landing, execute the CSC command or hold the throttle at its lowest position for 3 seconds or

more until the motors stop.

 10. Turn off the Intelligent Flight Battery first, followed by the Remote Controller. 

 

Special Event cinematography: 

Capturing those perfect moments during a special event is important. Capturing it with aerial 

cinematography will help give the host a professional recording to relive their special moments with out 

the dangers and expenses of a manned fixed wing aircraft or helicopter. 

Recording Special Events would be taken care of delicately with my UA. Firstly I, Thomas Goodall, 

would observe the flight area for any mobile phone base stations, radio transmission towers, power lines 

or any other electromagnetic interference that could disrupt flight. I would scan the area for any large 

buildings or trees that may affect with GPS accuracy or flight. lastly make sure the weather is flight ready 

to avoid wind speed exceeding 10m/s , snow, rain and smog also to be sure the UA and battery 

performance is subject to safe air density and temperature. Second go through the PRE FLIGHT 

CHECKLIST/maintenance and FLIGHT TEST PROCEDURES as normal in a secure area safe from 

persons and property. Thirdly capturing film from a safe distance from persons and property avoiding all 

crowds and hazards. 

Real Estate:

Arial cinematography in the housing market has been around for a long time through manned fixed wing 

aircraft and helicopters. For small budget real estate companies and average homeowners the expense of 
such aerial videography is cost prohibitive. Only large companies and high end Realtors or luxury 

homeowners can afford to absorb such expense. Depriving non-luxury homeowners and lower budget 

Realtors from a valuable marketing tool. Also using my UA avoids the high risks in a helicopter with 

fuel and persons on board. 

To make sure the operation will be safely conducted Firstly I, Thomas Goodall, would observe the flight 

area for any mobile phone base stations, radio transmission towers, power lines or any other 

electromagnetic interference that could disrupt flight. I would scan the area for any large buildings or 

trees that may affect with GPS accuracy or flight. I'd make sure the weather is flight ready to avoid wind 

speed exceeding 10m/s , snow, rain and smog also to be sure the UA and battery performance is subject to 

safe air density and temperature. Second go through the PRE FLIGHT CHECKLIST/maintenance and 

FLIGHT TEST PROCEDURES in a secure area safe from persons and property. Thirdly capturing film 

from safe distance from persons and property avoiding all hazards.

Its length x height x width dimensions without the propellers attached are 44 x 30 x 45cm (17.3 

x 11.8 x 17.7in). 

weight: Weight (Battery Included) 2935 g

Compliance: The Remote Controller is compliant with both CE and FCC regulations. stated on 

page 24 in DJI Inspire 1 flight manual attachment. 

Operating Frequency 922.7MHz~927.7 MHz 5.725~5.825 

GHz;2.400~2.483 GHz

This device complies with part 15 of the FCC Rules. stated on page 62 of the DJI Inspire flight 

manual.

the design and operational characteristics of the Inspire 1:

Three positioning modes; 

-GPS and vision positioning and uses GPS for positioning.

-Vision positioning is available but GPS is not 
-Neither GPS or vision positing is working and its only using its barometer for positing 

return to home are where you last record point of take off. There are three cases that will trigger 

RTH procedure; they are Smart RTH, Low Battery RTH and Failsafe RTH. 

Press and hold the button to start the Return to Home (RTH) procedure. Then the LED around 

the RTH Button will blink white to indicate the aircraft is entering RTH mode. The aircraft will 

then return to the last recorded Home Point. and to cancel it Press this button again and you 

will regain the control of the aircraft. 

Smart RTH: 

you may control the aircraft's orientation to avoid collision during the Smart RTH. Press the 

Smart RTH button once to start the process, press the Smart RTH button again to exit Smart 

RTH and regain the control. 

Low Battery RTH:

The low battery level failsafe is triggered when the DJI Intelligent Flight Battery is depleted to a 

point that may affect the safe return of the aircraft. Users are advised to return home or land the 

aircraft immediately when these warnings are shown. DJI Pilot app will advise user to return the 

aircraft to the Home Point when low battery warning is triggered. Aircraft will automatically return 

to the Home Point if no action is taken after 10 seconds countdown. User can cancel the RTH 

by pressing once on the RTH button. The thresholds for these warnings are automatically 

determined based on the current aircraft altitude and its distance from the Home Point.

Aircraft will land automatically if the current battery level can only support the aircraft to land to 

the ground from the current altitude. User can use the remote controller to control the aircraft’s 

orientation during the landing process.

The Battery Level Indicator is displayed in the DJI Pilot app, and is described below 

Failsafe RTH:

Failsafe RTH is activated automatically if remote controller signal (including video relay signal) 

is lost for more than 3 seconds provided that Home Point has been successfully recorded and 

compass is working normally. Return home process may be interrupted and the operator can 

regain control over the aircraft if a remote controller signal is resumed.

Max Height & Radius limit flying height and distance: 

The user may change these settings in the DJI Pilot App. Once complete, your Inspire 1 will fly 

in a restricted cylinder that is determined by these settings. The tables on page 45 in the flite 

manual attachment show the details of these limits.
On the DJI Inspire 1 as a default a “warning zone” has been set around safety zones. When you 

fly within 320 feet of the 5 mile radius of the restricted flying zone a warning message will 

appear on the DJI Pilot App. and there is a graph to show in detail on page 47 of Dji inspire 1 

flight manual attachment. That includes for category A areas and category B areas, big and 

small airports.

Respectfully Submitted,

Thomas Goodall,

210 Via Nada, San Clemente, CA.