Inspire Technologies, Inc. Sec tion 333 exemption request 10/20 /2015 Page 1 of 8 Submitted : October 20th 2015

U.S. Department of Transportation, Docket Operations

West Building Ground Floor, Room W12

- 140

1200 New Jersey Avenue, SE

Washington, DC 20590

Joseph J Hainey Jr



### – President

Inspire Technologies, Inc.

PO Box 85

2550 Sky Top Trail

Dover, PA 17315

717

- 467

- 0076

Regarding : Petition of Inspire Technologies, Inc. for Exemption Pursuant to section 333 of the FAA

Reform Act



### Attn: To whom it may concern

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the Reform Act)

and 14 C.F.R . Part 11, Inspire Technologies, Inc.

, request the use of Small Unmanned Aircraft

Systems (sUASs ) to conduct aerial photography and videography, hereby ap plies for an

exemption from the listed Federal Aviation Regulations ("FARs") to allow commercial operation

of its sUASs , so long as such operations are conducted within and under the conditions outlined

herein or as may be established by the FAA as require d by Section 333.1

As described more fully below, the requested exemption would permit the operation of small,

unman ned and relatively inexpensive SUASs under controlled conditions in airspace that is

The proposed exemption, if granted, would allow Inspire Technologies, Inc. , to conduct

commercial operations of SUAS meeting or exceeding all of the operational and safety

requirements Congress has set forth in Section 333.

Inspire Technologies, Inc. is a t echnology company that plans to use the capabilities of Unmanned

Aerial Systems to offer a multitude of services, including:

• Aerial surveying

• Remote sensing

• Agricultural support

• Real Estate Photography

• Aerial filmmaking and photography

• Construction site inspections and monitoring

• Wildlife and forestry monitoring

• Educational and research operations

• S earch and rescue operationsInspire Technologies, Inc. Sec tion 333 exemption request 10/20 /2015 Page 2 of 8 Statutory Authority Section 333, titled “Special Rules for Certain Unmanned Aircraft Systems ”,

provides a mechanism for seeking expedited FAA authorization of safe civil UAS operations in the

NAS. Section 333(a) states that the FAA “shall determine if certain unmanned aircraft systems may

operate safely in the national airspace system before completion of the (comprehensive) plan and

rulemaking required by section 332(b)(1) of this Act or the guidance required by section 334 of this

Act.” In Section 332 (b) (1) , Congress made it clear that Section 333 provides a mechanism for

“expedited operation authorization” if several factors are met. Petitioner meets all requirements to

permit FAA approval of commercial UAS operations

.

The Petitioner Requests Relief from the f ollowing :

14 C.F.R. Part 21

14 C.F.R. 45.23 (b)

14 C.F.R. 61.23(a) & (c);

14 C.F.R. 61.101(e) (4), & (5);

14 C.F.R. 61.113(a) and (b)

14 C.F.R. 61.133 (a);

14 C.F.R. 91.7 (a)

14 C.F.R. 91.9 (b) (2)

14 C.F.R. 91.103

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) & ( b)

14 C.F.R. 91.205 (b)

14 C.F.R. 91.215

14 C.F.R. (91.401

- 91.417 )

Small Unmanned Aircraft System s

sUASs are oftentimes seen as superior to helicopters due to the smaller devices cheaper

equipment and personnel cost, reduced noise and as such, a much smaller environmental impact

which promotes public safety.

We are petitioning for exemption to enable



### , In spire Technologies, Inc. to operate a DJI Inspire 1

equipped with a three

- axis gimbals and using High

- Def cameras. This sUAS has a built

- in capability

to limit the height it flies above the ground, to limit the radius of the distance it flies from the

op erator and to exclude it from Class B, C and D airspace including a no

- fly zone feature.

The above specifications meet with the Model Aircraft Operating Standards as set below:



### Inspire Technologies, Inc

. will only operate its sUASs in line of sight of a pilot and/or observer and will

operate at sites that are a 'sufficient distance' from populated areas within the sterile area

described in the FOPM. Such operations will insure that the sUAS will "not create a hazard to users

of the national a irspace syste m or the public."

When flying s UASs within 5 miles of an airport, airport operators will be notified and the operatorInspire Technologies, Inc. Sec tion 333 exemption request 10/20 /2015 Page 3 of 8 will give the right of way to avoid flying in the proximity of full

- scale aircraft.

• Maximum flight time for each operational flight will be 20 minutes.

• F lights will be terminated at 25% battery power reserve should that occur prior to the 20

minute limit.

• The sUASs will be programmed so that it will not be operated at an altitude of no more than

400 feet AGL

.

• The sUASs weighs less than 55 pounds, including the payload (i.e. camera, lens, and

gimbal).

• The sUASs will operate at speeds of no more than 50 knots, can hover, and can

simultaneously move vertically and horizontally.

• Given the small size of the sUASs and t he restricted sterile environment within w hich they

will operate, our sUASs operations adhere to the Reform Act's safety requirements.

The UA, powered by batteries, is smaller, lighter and more maneuverable than larger aircraft

running on combustible fuel, it operates at lower altitudes with no people on board and will

thereby reduce current risk levels and thereby enhance safety and dimi nish the likelihood of death

or serious bodily injury. With a small payload and maximum flight time of only 20 minutes

, this is

offers little or no risk to national security.

Low level oblique photos and video from several angles are far more effective th an ground based

imagery for displaying the characteristics of large, complex properties with several buildings and

large trees. The applicants in the past have chartered 2

- seat full

- sized helicopters for this purpose,

which has proven more costly than many potential clients have been able to afford. The benefits of

reduced cost and improved quality of presentation from the UA will be valuable to and benefit

many buyers and sellers of real property.

Additionally, we request that we be allowed to use our system to benefit first responders nearby

who might require assistance, including fire fighters, the police, the sheriff, et al., while remaining

subject to all limitations cited in this application as we do so.

• No flight will be made with a Gross weight exceeding 55 pounds ;

• All operations must occur in FAA Class G airspace at no more than 400 f ee t AGL, at an

airspeed of no more than 25 knots ;

• All operations must utilize a visual observer ( VO). The VO and PIC must be able to

communicate by voice at all times during a flight operation;

• Operations will be restricted to flights over private property with the permission of the

property owner;

• All required permits will be obtained from state and local government prior to operation;

• Inspire Technologies, Inc. will not be operate over densely populated areas;

• Inspire Technologies, Inc. will not be operating over any open

- air assembly of people;

• Inspire Technologies, Inc. will not be operating over heavily tracked r oads;

• Inspire Technologies, Inc. will not be operating within 5 NM of an airport or heliport without

prior permission.

We respectfully request exemption under Section 333 to enable, 

### Inspire Technologies, Inc. , to

operate efficient, limited, low

- risk commercial sUASs operations for the activities stated respecting

at all times the space and privacy of citizens and property whilst keeping our skies safe.

Sincerely

,Inspire Technologies, Inc. Sec tion 333 exemption request 10/20 /2015 Page 4 of 8 Joseph J. Hainey Jr.Inspire Technologies, Inc. Sec tion 333 exemption request 10/20 /2015 Page 5 of 8 EXEMPTION REQUESTS AND EQUIVALENT LEVEL OF SAFETY

Inspire Technologies, Inc. requests an exemption from the following regulations as well as any

additional regulations that may technically apply to the operation of the sUASs System:

14 CFR Part 21, Airworthiness Certificates

. This part establishes the procedures for the issuance of an airworthiness certificate. While the FAA

continues to work to develop airworthiness standards for Unmann ed Aerial Systems, we request an

experimental certificate be issued for the DJI Phantom 3 under either or both of the following

provisions:

21.191 Experimental certificates

, Experimental certificates are issued for the following purposes:

(a) Research and development

. Testing new aircraft design concepts, new aircraft equipment, new aircraft

installations, new aircraft operating techniques, or new uses for aircraft.

(b) Showing compliance with regulations

. Conducting flight tests and other operations to show

compliance with the airworthiness regulations including flights to show compliance for

issuance of type and supplemental type certificates, flights to substantiate major design

changes, and flights to show compliance with the function and reliability r equirements of the

regulations. Since the experimental certificate can be used for commercial purposes such as

market surveys, sales demonstrations, and customer crew training, we would expect that an

experimental certificate would permit our commercial pu rpose as well. The aircraft will not

carry persons or property, will not carry fuel, and will only fly under strict operational

requirements. Combined with the UA's light weight, being constructed primarily of carbon

fiber and plastic, we propose that the UA will be at least as safe, if not safer, than a

conventionally certificated aircraft performing the same mission. If an experimental

airworthiness certificate is not appropriate for this application, then we request an

exemption of 14 CFR Part 21, Subpart H, and the requirement for an airworthiness certificate

in general, citing the equivalent level of safety outlined in the previous paragraph

.

14 CFR 45.23 Display of marks; general and 45.29 Size of marks.

These regulations provide that each aircraft must display "N" and the aircraft's registration number in

letters at least 3 inches high. Additionally, the aircraft must display the word "EXPERIMENTAL" in

letters at least 2 inches high near the entran ce to the cabin, cockpit, or pilot station. The sUASs does

not have an entrance in which the word "EXPERIMENTAL" can be placed, and may not have a

registration number assigned to it by the FAA. We propose to achieve an equivalent level of safety

by including the word "EXPERIMENTAL" in the placard on the top of the aircraft, as shown above,

where the PIC (Pilot in Command ), VO (Visual Observer) and others in the vicinity of the aircraft while

it is preparing for launch will be able to see the de signation. Additionally, we feel that the

permanent placard discussed in the previous paragraph will provide the aircraft's registration

information at the ground station.

14 CFR 61.113 Private pilot privileges and limitations :

Pilot in Command and 6 1.133 Commercial pilot privileges and limitations. The regulation provides

that no person that holds a Private Pilot certificate may act as pilot in Command of an aircraft for

compensation or hire. Subparagraph (b) allows a private pilot to act as pilot in command of an aircraft

in connection with any business or employment if: (1) The flight is only incidental to that business or

employment; and (2) The aircraft does not carry passengers or property for compensation or hire.Inspire Technologies, Inc. Sec tion 333 exemption request 10/20 /2015 Page 6 of 8 Our proposed operations require that the PIC must hold at least a Private Pilot Certificate issued by

the FAA and since the aircraft cannot carry passengers or property, we feel we meet the intent of

61.113 Subparagraph (b) even though the intent of this application is to conduct a business.

14 CFR 91.7 Prohibits the Operation of an aircraft without an airworthiness certificate

. As no such certificate

will be applicable in the form contemplated by the FARs, this Regulation is inapplicable.

14 CFR 91.9 Civil aircraft flight manual, marking, and placard requirements . This regulation provides

that no person may operate an aircraft unless a current, approved flight manual is in the aircraft.

We assume that the intent of this requirement is to ensure that flight manual information is available

to the aircrew while operatin g the aircraft. We request an exemption to this requirement since the

aircraft is not only too small to carry documentation, the documentation would not be available to

the crew during flight operations. To obtain an equivalent level of safety an d meet the intent of

91.9, we propose that a current, approved sUAS Flight Manual must be available to the crew at the

ground station anytime the aircraft is in, or preparing for, flight.

14 C.F.R. § 91.103: Preflight Action. Section 91.103 requires each PIC to take certain actions before flight

to insure the safety of flight. As FAA approved Rotorcraft flight manuals will not be provided for the

aircraft an exemption will be needed. The PIC will take all actions as stated in the manufacturer FOM in the

pr eflight inspection section, including but not limited to reviewing weather, flight battery requirements,

landing and takeoff distances and aircraft performance data before initiation of flight.

14 CFR 91.109 Flight Instruction; Simulated instrument flight and certain flight tests The regulation

states that "No person may operate a civil aircraft that is being used for flight instruction unless

that aircraft has fully functioning dual controls." The sUASs System ground

- based control station

consists of a small hand

- held radio transmitter and while it does not offer a second set of "controls",

both the student and instructor can, and will, operate the single set of controls simultaneously. With

both student and instructor having "hands

- on" the controls du ring flight, we feel that this technique

meets the intent 91.109 and provides an equivalent level of safety

.

91.119 Minimum safe altitudes : General. The regulation states that over sparsely populated areas

the aircraft cannot be operated closer than 500 f eet to any person, vessel, vehicle, or structure. Since

the typical mission of the sUASs would be photography or survey of persons, vessels, vehicles or

structures it would be necessary to operate closer than 500 feet to the items listed. Operations will

o nly be flown over property or persons where permission has been obtained and careful pre

planned has been performed. The aircraft will be operated at a low altitude allowing, if a power unit

fails, an emergency landing without undue hazard to persons or property on the surface. Therefore

we maintain that due to the small size of the UAS, the hazard to persons, vehicles and structures is

minimal compared to manned aircraft, which should be considered in granting the exemption

.

CFR 91.121 Altimeter settings . The regulation requires that aircraft shall maintain cruising altitudes

by reference to an altimeter setting available within 100 NM of the aircraft. The sUASs will always fly

below 400 feet AGL and will not need to maintain cruising altitudes in order to prevent conflict with

other aircraft

14 CFR 91.151 Fuel requirements for flight in VFR conditions. The regulation provides that no person

may begin a f light in an airplane under day

- V FR conditions unless there is enough fuel to fly to the

fi rst point of intended landing and to fly after that for at least 30 minutes. We feel the intention of

this paragraph is to provide an energy reserve as a safety buffer for delays to landing. The sUASs isInspire Technologies, Inc. Sec tion 333 exemption request 10/20 /2015 Page 7 of 8 battery operated and the maximum duration of flight from a single battery charge is 18 minutes with

a 20% reserve. Since the aircraft will never fly more than 1/8 NM from the point of intended

landing, a full battery charge at launch will ensure that we meet the reserve energy requirement of

this paragraph. We request an exemption to the word "fuel" and ask for an equivalent interpretation

with the word "energy".

14 CFR 91.203(a) & (b) Civil aircraft: Certifications required. The regulation provides tha t an

airworthiness certificate, with the registration number assigned to the aircraft and a registration

certificate must be aboard the aircraft. Additionally , subparagraph (b) provides that the airworthiness

certificate be "displayed at the cabin or cockp it entrance so that it is legible to passengers or crew."

At a maximum gross weight of 5.3 pounds , the sUASs is too small to carry documentation, does not

have an entrance, and is not capable of carrying passengers or crew. To obtain an equivalent level of

safety and meet the intent of 91.203, we propose that documents deemed appropriate for this

aircraft by the FAA will be co

- located with the crew at the ground control station and available for

inspection upon request. In order to identify the aircraft, we propose that the information found on

airworthiness and registration certificates be permanently affixed to the aircraft via placard

containing the following information plus the word "EXPERIMENTAL" to satisfy the requirement of

14 CFR 45.23.

14 CFR Subpart E (91.401

- 91.417)

- Maintenance, Preventive Maintenance, Alterations

. The regulation

provides that the operator is primarily responsible for maintaining the aircraft in an airworthy condition,

including compliance with part 39 and 43. Paragraphs

91.407 and 91.409 require that the aircraft be "approved for return to service by a person authorized

under 43.7" after maintenance and inspection. It is our intention that the PIC perform maintenance

and inspection of the aircraft and "be aut horized to approve the aircraft for return to service." The

PIC will ensure that the aircraft is in an airworthy condition prior to every flight and in addition

conduct detailed inspections after every two hours of flight. Maintenance performed by the P IC is

limited to repairing small cracks, replacing a propeller, checking electrical connections and updating

software and firmware for the on

- board computer. All other maintenance will be performed by the

manufacturer or their designated repair facility. The PIC will document work performed in

accordance with 91.417. We feel that due to the size, construction, and simplicity of the aircraft, the

PIC can ensure an equivalent level of safety.

Safety and Benefits of the sUASs

Inspire Technologies, Inc. will be using the sUASs in a variety of applications that generally require

expensive full

- size manned aircraft to complete. Small, light, unmanned aerial vehicles offer myriad

benefits over the use of full

- sized manned aircraft for electric power line ins pection, oil/gas pipeline

inspection, advanced agriculture, film and still photography, just to name a few. Replacing

significantly larger manned aircraft carrying crew and flammable fuel with small UAS carrying no

passengers or crew creates a much gre ater margin of safety for the pilots and crew. By granting

Inspire Technologies, Inc. requested exemptions, the FAA will help drive development of safe and

successful commercial UAS operations and will advance the public knowledge base for such

o perations. Inspire Technologies, Inc. is committed to promoting the UAS research efforts of

policymakers including the FAA, NASA, DOD and DARPA by sharing data from its commercial UAS

operations and serving as a resource for future UAS research operatio ns. Thus, the FAA has good

cause to grant this Petition.Inspire Technologies, Inc. Sec tion 333 exemption request 10/20 /2015 Page 8 of 8 Conclusion

As pointed ou t in this application, all the sUASs which our company would use, under authorization

by the US DOT

- FAA, are small, light

- weight devices operated within the line of sight of the Pilot

- in

Command (PIC), less than 400 feet above the ground and outside 5 miles from any airport, heliport,

seapla ne base, spaceport, or other location with aviation activities, unless the air traffic control

authorities (ATC) have been notified and have authorized each flight within a radius of this distance.

All our SUAs have proven capability for controlled flight. They are devices offered for general sale on the

market around the world and have often been used as Model Aircraft in the USA. We are certain that the

studies conducted until now by the FAA, about Section 332, Public Law 112

- 95, 2014, have already

provided you with the assura nces on the airworthiness of sUASs such as ours.

For the foregoing reasons, the exemptions requested herein should be granted and Inspire

Technologies, Inc. should be permitted to conduct small SUASs operations in accordance with its

manuals and all other operating parameters deemed necessary and appropriate by the FAA. The

submission of this application and its contents is the best demonstration that indeed it is possible to

pursue the authorization process so that some SUAs may be used for legitimate commercial activities and

under reasonably safe conditions.