March 3, 2016 

ODN, Inc.: 

Gregory Heifner 

Exemption request to section 333 of the FAA Reform Act of 2012 

Dear Sir or Madam: 

 In regards to section 333 of the FAA Reform Act of 2012 and C.F.R Part 11. My 

registered business ODN, Inc, I am the owner and operator. ODN, Inc. would like to 

move into the Small Unmanned Aircraft Vehicals (UAVs), requests to be exempted from 

the Federal Aviation Regulations (FARs) listed below so that ODN, Inc. may operate 

UASs commercially in airspace regulated by Federal Aviation Administration; as long as 

such operations are conducted under the conditions of the FAA that are required by 

section 333. ODN, Inc. works exclusively with public safety in the USA and Canada. 

 

 ODN, Inc.is owned by Gregory Heifner, and is the leading supplier of satellite 

communications for agencies across the US and Canada. ODN, Inc. has been moving 

into aerial photography and the aerial inspection markets (tower and bridge 

inspections). I, Gregory Heifner, have over 1000 hours of flight time with the DJI Inspire 

series UAVs, as well as others and all of the work that I have done to date has been for 

personal enjoyment and education of how to properly and safely fly a drone as well as 

demoing their capability to law enforcement and fire. All of my flights will adhere to the 

FAA’s Flight Photography Standard Operating Procedures (SOPs). 

 

My contact info: 

Gregory F. Heifner 

ODN, Inc. 

Address: 4451 I-70 Drive NW, Columbia, MO, 65202 

Phone: 573-445-8101 

Email: greg.heifner@orbitaldata.net 

Drone registration number: FA37RPMRAF 
Gregory F. Heifner holds a private pilot license with multi-engine instrument ratings 

and Glider and Tow endorsements. He has approximately 6000 hours as PIC.

The exemption that I am asking for would permit the operation of any of the DJI 

UAVs, under controlled conditions for commercial use by Gregory Heifner. ODN, Inc. 

requests with respect to the FAA to grant an exemption to the following specific sections 

of the Title 14 Code of federal Regulations allowing it to operate the DJI Inspire series 

drones which are light weight UAV’s for commercial use. 

 

14 CFR 21, subpart H, 

14 CFR 45.23(b), 

14 CFR 91.7(a), 

14 CFR 91.9(b)(2), 

14 CFR 91.103(b), 

14 CFR 91.109, 

14 CFR 91.119(c), 

14 CFR 91.121, 

14 CRF 91.151(a), 

14 CFR 91.203(a)&(b), 

14 CFR 91.405(a), 

14 CFR 91.407(a)(1), 

14 CFR 91.409(a)(2), 

14 CFR 91.417(a)&(b), 

14 CFR 61.113(a)&(b), 

61.23(a) and (c), 

61.101(e)(4) and (5), 

61.113(a), 61.315(a), 

ODN, Inc. submits this application in accordance with the Reform Act, 112 P.L. 95 

331334, seeking relief from any currently applicable FARs operating to prevent 

commercial cinematic, tower and bridge inspection, training and other flight operations 

within the national airspace system. The Reform Act in Section 332 provides for such 
integration of civil unmanned aircraft systems into our national airspace system as it is 

in the public’s interest to do so. All public safety flight operations will be done with full 

permission and oversight from the agencies responsible for those public assets. Any 

airspace within 5 miles of an airport or heliport will be contacted for permission to 

operate before any flight commences. 

ODN, Inc., uses the DJI series UAVs that meet the definition of “small unmanned 

aircraft” as defined in Section 331 and therefore the integration of the ultra-light weight 

UAV is expressly contemplated by the Reform Act. The Reform Act guides the 

Secretary in determining the types of UAV's that may operate safely in our national 

airspace system. Considerations include: The weight, size, speed and overall 

capabilities of the UAV's; whether the UAV will be operated near airports or heavily 

populated areas; and, Whether the UAV will be operated by line of sight. 112 P.L. 95 

333 (a). Each of these items are in favor of an exemption for ODN, Inc.. ODN, Inc. 

UAVs utilizes four (4) counter-rotating propellers for balance, control and stability. Their 

UAV is equipped with GPS and auto return safety technology. Weighing less than ten 

(10) pounds (far below the maximum 55 pound limit); including camera. 

Attached is link to DJI Inspire Pro specs and flight manuals; 

http://www.dji.com/product/inspire-1-pro-and-raw/info#specs

http://dl.djicdn.com/downloads/inspire_1_pro/en/Inspire_1_Pro_User_Manual_en_v1.0_

1201.pdf

Considerations when Operating 

Starting the spring of 2016 ODN, Inc. would be taking aerial photography / video of 

• Bridge inspection for Departments of Transportation 

• Deactivated towers inspection for Highway Patrols and other emergency 

agencies 

• Search and Rescue 

• Natural disaster scene evaluation 

• Training in operation of UAV’s 

• Aerial mapping 
• FLIR operations near fires in support and cooperation with the authority on the 

scene 

• Aerial photography and video streaming 

Consideration of Risk Management 

• All flights are operated with in line of sight 

• Flights will take place during the daytime 

• Flights will terminated once the battery reaches 20% 

• Full site surveys will be conducted prior to the flight 

• If the UAV loses sight or GPS signal is lost, it will automatically return to the 

home location and land 

• If the UAV Battery reaches 20% it will automatically return to the home location 

and land 

• UAVs are equipped with ‘First-Person-View’ (FPV) 

• Fights will be canceled due to high winds, rain, and snow 

• UAV’s will have a pre-flight check on all parts, as well as the most recent 

firmware loaded 

The DJI Inspire is equipped with sensors for indoor flight for safety and control. Any 

indoor flights will have written permission as well as no people are to be in the indoor 

area where the flight is taking place, except for the pilot and camera operator. 

All flights will be accomplished with a PIC within view of the UAV, as well as a safety 

observer/camera operator (VO). 

The Coalition commented that a visual observer (VO) should not be required for all 

small UAV operations. The Coalition further asserted that the presence of one or more 

VOs may allow the UAV to be operated beyond visual line of sight (VLOS) of the pilot in 

command (PIC) and that the petitioner’s proposal to operate the unmanned aircraft (UA) 

within VLOS of the PIC and/or VO should be permitted. The FAA notes that one of the 

determinations for operations under section 333 is operation within visual line of sight. 

The PIC must maintain VLOS while operating the UA. The FAA may find that a VO 

complements the PIC’s capability to see and avoid other aircraft, including when the 
PIC may be momentarily attending to other flying tasks. The VO provides an additional 

level of operational safety. 

About Gregory Heifner

Mr. Heifner is a well acknowledged pioneer in satellite communications. After the 9/11 

attacks, he dedicated his life to the use of communication satellites in public safety 

communication networks. Currently his system protects millions of people throughout 

the nation, allowing 911 calls to be answered even in sever circumstances where a 

natural disaster has rendered all other channels of communication as worthless. The 

addition of UAV’s is an offshoot of 50 years in RC aircraft, 45 years as a multi-engine, 

instrument rated, private pilot and my desire to use UAV’s to save lives. 

See: www,orbitaldata.net 

 

Benefits for the community

• ODN, Inc. will provide for safer tower inspections where no life is put at risk. 

• ODN, Inc. will provide for safer bridge inspections where no life is put at risk. 

• ODN, Inc. will provide quality flight training to public safety personnel. 

• ODN, Inc. will safely bring the use of UAV’s to public safety to save lives and 

property. 

• ODN, Inc. will make small UAV’s available to search and rescue operations. 

Query 

ODN, Inc. with the guidance of the FAA, would like recommendations on the use of 

UAV’s at night with FLIR cameras attached for fire fighters. This technology can sense 

roofs that are about to burn thru, one of the leading causes of death to fire fighters. 

 

Sincerely 

Gregory Heifner 

4451 I-70 Drive NW 

Columbia, MO 65202