UNITED STATES OF AMERICA DEPARTMENT OF TRANSPORTATION

FEDERAL AVIATION ADMINISTRATION

WASHINGTON, DC

IN THE MATTER OF THE PETITION FOR EXEMPTION OF:

Inspired Aerials, 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 CARBON CORE QUADCOPTER/DJI INSPIRE 1

UNMANNEDAIRCRAFT SYSTEMS

PURSUANT TO SECTION 333 OF

THE FAA MODERNIZATION AND REFORM ACT OF 2012 (PUBLIC LAW 112-95)

Submitted on July 29, 2015

Matthew Ward Johnson

9 Maple Springs Ct.

Columbia, SC 29223

803-463-1247
2

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 8

THE SPECIFIC SECTIONS OF 14 C.F.R. FROM WHICH 

Matthew Ward Johnson SEEKS EXEMPTION 8

THE EXTENT OF RELIEF Matthew Ward Johnson SEEKS AND THE REASON

Matthew Ward Johnson SEEKS THE RELIEF 12

THE REASONS WHY GRANTING Matthew Ward Johnson’s REQUEST WOULD

BE IN THE PUBLIC INTEREST 15

THE REASONS WHY GRANTING THE EXEMPTION WOULD NOT ADVERSELY

AFFECT SAFETY 18

SUMMARY THAT CAN BE PUBLISHED IN THE FEDERAL REGISTER 34

ANY ADDITIONAL INFORMATION, VIEWS, OR ARGUMENTS AVAILABLE TO

SUPPORT Matthew Johnson’s REQUEST 35

CONCLUSION 35

APPENDICES 37
3

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
4

SUMMARY

Matthew Ward Johnson 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 him to operate an Unmanned Aircraft 

System (UAS) for the commercial purpose of conducting aerial video and photography of real 

estate and landscape over certain areas of the United States.

INTRODUCTION AND INTERESTS OF THE PETITIONER

Matthew Ward Johnson provides his clients with expertise and knowledge in advanced

photography and video solutions for a variety of public and private uses. Matthew Ward Johnson

has over 10 years of experience in photographic and video technology with over 5 years

recreational and hobby experience in all aspects of aerial video and photography. The objective 

of Matthew Ward Johnson’s aerial video and photography business is to provide high quality 

imaging for a variety of commercial, public, and residential uses, specifically targeting:

Retail businesses that desire aerial views of their establishments

Events

Real-estate marketing

Aerial acquisitions used for land surveying

Aerial photography and video for commercial and residential projects

Aerial acquisitions used for inspections of public and private structures
5

BACKGROUND

Unmanned Aircraft Systems: DJI Inspire 1 -- Matthew Ward Johnson seeks an 

exemption to operate DJI Inspire 1, Model T600, for compensation or hire within the NAS. The 

DJI Inspire 1 is a vertical takeoff and landing (VTOL) Unmanned Aircraft (UA) with a Ground 

Control Station (GCS) and remote controller at an operating frequency of 5.725~5.825 GHZ; 

2.400~2.483 GHZ. 

The DJI Inspire 1 has a maximum gross weight (battery included) of approximately

2935g. Without the propellers attached it has a length of 17.3 inches, height of 11.8 inches and 

width of 17.7 inches. The Inspire 1 uses 3510 motors and 1345 propellers and can achieve a 

maximum speed of approximately 22 m/s (ATTI mode, no wind). Inspire 1 is equipped with 4 

main rotors utilizing Lithium Polymer batteries. The Inspire 1 that will be operated by Matthew 

Ward Johnson 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

Petitioner, Matthew Ward Johnson, 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 Inspire 1 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).6 In 

consideration of the speed, weight, size, and limited operating area associated with the unmanned 
6

aircraft and its operation, Matthew Ward Johnson’s operation of the Inspire 1 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, Matthew Ward Johnson 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. Matthew Ward 

Johnson submits that the requested relief is proper since an equivalent level of safety will be 

ensured. Matthew Ward Johnson will use experienced personnel or technicians to perform 

maintenance, alterations, or preventive maintenance on the UAS's using the methods, techniques, 

and practices prescribed in the operating documents (i.e., Monthly Maintenance Log, and DJI 

Inspire 1 Instruction Manual). Furthermore, Matthew Ward Johnson will document and maintain 

all maintenance records for the DJI Inspire 1. 

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

privileges and limitations: Pilot in command, is requested by Matthew Ward Johnson to the 

extent necessary to allow a Pilot in Command (PIC) holding a private pilot or higher level 

certificate, as well as an airman 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 I in a manner consistent with this exemption. Matthew Ward Johnson has achieved over 

100+ hours of hobby, recreational operation with various UASs including the DJI Inspire 1 and 

as the Pilot in Command (PIC) he is able to safely operate the DJI Inspire 1 in a manner 

consistent with this exemption, including evasive and emergency maneuvers and maintaining 

appropriate distances from people, vessels, vehicles and structures. 
7

Matthew Ward Johnson seeks relief from Section 91.7(a), entitled Civil aircraft

airworthiness, because the DJI Inspire 1 does not require an airworthiness certificate in

accordance with 14 C.F.R. Part 21, Subpart H. As such, Matthew Ward Johnson submits that he

will ensure that the DJI Inspire 1 is in an airworthy condition, prior to every flight, by

determining that the UAS's are in compliance with the operating documents (i.e., Monthly

Maintenance Log, and DJI Inspire 1 Instruction Manual), and that the aircraft are in a condition 

for safe flight.

Matthew Ward Johnson also seeks an exemption from the requirements of Section 

91.121, entitled Altimeter Settings, as the DJI Inspire 1will not have a typical barometric 

altimeter onboard. However, altitude information of the DJI Inspire 1 will be provided to the 

PIC via Global Positioning System (GPS) equipment and radio communications telemetry data 

link, which downlinks from the UAS to the GCS for active monitoring of the flight path. This

altitude information, combined with Matthew Ward Johnson’s operation of the DJI Inspire 1

within visual line of sight, at or below 400 feet AGL, will ensure a level of safety equivalent to 

Section 91.121. 

Additionally, Matthew Ward Johnson seeks an exemption from the requirements of 

Section 91.151(b), entitled Fuel requirements for flight in VFR conditions. Matthew Ward 

Johnson submits that safety will not be affected by operation of the DJI Inspire 1 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 18 minutes with the time for the

intended photo shoot taking no more than 10 to 15 minutes and always reserving no less than 3 

minutes of battery life at normal cruising speed for flying time for recovery and landing. 
8

In accordance with 14 C.F.R. § 11.81, Matthew Ward Johnson provides the following

information in support of its petition for exemption:

A. Name and Address of the Petitioner

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

Matthew Ward Johnson, 9 Maple Springs Ct., Columbia, SC 29223; 803-463-1247

Email: bmwjohnson13@yahoo.com

B. The Specific Sections of 14 C.F.R. From Which Matthew Ward Johnson seeks 

Exemption

1. Matthew Ward Johnson 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. Matthew Ward Johnson 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. Matthew Ward Johnson Seeks Exemption From The Requirements Of Section 91.121.
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Section 91.121, entitled Altimeter settings, subsection (a), states the following, in part:

(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. Matthew Ward Johnson Seeks Exemption From The Requirements Of Section91.151 (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. Matthew Ward Johnson Seeks Exemption From The Requirement Of Section91.405 (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[.]
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6. Matthew Ward Johnson 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:

(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. Matthew Ward Johnson 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. Matthew Ward Johnson 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:
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(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:

(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.
12

(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 Matthew Ward Johnson Seeks And The Reason Matthew Ward 

Johnson Seeks The Relief.

1. Extent of Relief Matthew Ward Johnson Seeks and The Reason Matthew Ward Johnson

Seeks Relief from Section 61.113(a) and (b)

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 holding a private pilot or 

higher level certificate, as well as a current and valid airman medical certificate, and 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, Matthew Ward Johnson submits that an equivalent level of

safety will be maintained because no PIC will be allowed to operate the DJI Inspire 1 unless that 
13

PIC has met certain flight-hour and current requirements, demonstrating that the PIC is able to 

safely operate either the DJI Inspire 1 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, 

Matthew Ward Johnson submits that all flights of the DJI Inspire 1 conducted by the PIC

pursuant to the grant of this Petition will: (1) be incidental to Matthew Ward Johnson’s business;

and (2) will not carry passengers or property for compensation or hire.

2. Extent Of Relief Matthew Ward Johnson Seeks And The Reason Matthew Ward 

Johnson From Section 91.7(a)

Relief from Section 91.7(a) entitled Civil aircraft airworthiness, is requested to the extent 

required to allow Matthew Ward Johnson to determine that the DJI Inspire 1 are in airworthy 

condition prior to every flight by ensuring that the UAS is in compliance with the operating 

documents (i.e., the Monthly Maintenance Log and DJI Inspire 1 manuals. Matthew Ward 

Johnson seeks the requested relief because the DJI Inspire 1 does not require an airworthiness 

certificate in accordance with 14 C.F.R. Part 21, Subpart H. Therefore, Matthew Ward Johnson

will ensure that the DJI Inspire 1 is in airworthy condition based upon its compliance with the 

operating documents (i.e., Monthly Maintenance Log, and DJI Inspire 1 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 Matthew Ward Johnson Seeks And The Reason Matthew Ward 

Johnson Seeks Relief From Section 91.121.

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

operations of the DJI Inspire 1 UAS's, which utilize a barometric pressure sensor, GPS
14

equipment, and a radio communications telemetry data link to downlink altitude information

from the UA to the PIC at the ground control station (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), Matthew Ward Johnson seeks the requested relief because the DJI

Inspire 1’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 is 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 Relief Matthew Ward Johnson Seeks And The Reason Matthew Ward 

Johnson 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 during 

daylight hours in visual meteorological conditions (VMC), under visual flight rules (VFR), for a 

total duration of 15 minutes to the first point of intended landing and, assuming normal cruising 

speed, to fly after that for at least 3 minutes. Matthew Ward Johnson seeks the requested relief 

because without an exemption from Section 91.151(b), the flight time duration of the battery 

powered DJI Inspire 1 will severely constrain the practicality of any aerial video or still photo 

flight operations that Matthew Ward Johnson proposes to conduct pursuant to this Petition. 

Significantly, as set forth below, the technical specifications of the DJI Inspire 1
15

operating documents and Matthew Ward Johnson’s proposed operating limitations, ensure that

Matthew Ward Johnson will safely operate the battery powered DJI Inspire 1 during daylight

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

battery power to fly for a total duration of 15 minutes to the first point of intended landing and, 

assuming normal cruising speed, to fly after that for at least 3 minutes.

5. Extent Of Relief Matthew Ward Johnson Seeks And The Reason Matthew Ward 

Johnson 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, Matthew Ward Johnson requests relief from 

these Sections because the DJI Inspire 1 does not require airworthiness certificates. As set forth 

more fully below, the DJI Inspire 1 meets the conditions of FMRA Section 333 for operation 

without an airworthiness certificate. Accordingly, Matthew Ward Johnson will use trained 

technicians to perform maintenance, alterations, or preventive maintenance on the UAS's using 

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

Aerial Operations Manual, Monthly Maintenance Log, and DJI Inspire 1 Instruction Manual). 

Furthermore, Matthew Ward Johnson will document and maintain all maintenance records for 

DJI Inspire 1.

D. The Reasons Why Granting Matthew Ward Johnson’s Request Would Be In The Public 

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

Granting the present Petition will further the public interest by allowing Matthew Ward 

Johnson to safely, efficiently, and economically perform aerial video and photography of

construction sites, real estate, and landscape over certain areas of the United States. 
16

Additionally, use of the DJI Inspire 1 will decrease congestion of the NAS, reduce pollution, and 

provide significant benefits to the economy. Notably, the benefits of Matthew Ward Johnson's

proposed operation of the DJI Inspire 1 will be realized without implicating any privacy issues.

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

The DJI Inspire 1 is battery powered and serves 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 the DJI Inspire 1 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 does 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.

2. The Public Will Benefit From The Safety And Efficiency Of The DJI Inspire 1.

Conducting aerial acquisitions with the DJI Inspire 1 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. By using battery power 

and electric motors, the DJI Inspire 1 produces no air pollution, and is the most viable 

environmentally conscious alternative to the cabin class, six cylinder internal combustion engine 

aircraft that are typically utilized for aerial video and photography while burning approximately 

20-30 gallons per hour of leaded aviation fuel. The DJI Inspire 1, while reducing the carbon 
17

footprint of aerial acquisitions, also eliminates noise pollution, as the UA's are propelled by 

battery powered electric motors, rather than an internal combustion engine.

By using the DJI Inspire 1 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. Aside from the lack of 

flight crew members located onboard the aircraft, the DJI Inspire 1 weighing approximately 2935 

g and with no fuel on board has less physical potential for collateral damage to life and property 

on the ground, and in the air, compared to the manned aircraft that typically conduct similar

operations weighing approximately 6,000 pounds with a fuel capacity of 180 gallons.

3. Performing Aerial Video and Photography Operations with the DJI Inspire 1 Will

Benefit the Economy.

In addition to being safe and efficient, the DJI Inspire 1 is also an economical alternative 

to using manned aircraft to conduct similar aerial operations. As such, operation of the DJI 

Inspire 1 will allow United States based companies, like Matthew Ward Johnson’s 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 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. 

By operating the DJI Inspire 1, companies such as Matthew Ward Johnson’s can remain

competitive and profitable and therefore, provide greater job stability to employees and
18

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, 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.

4. There Are No Privacy Issues.

Similar to the manned aerial acquisition flight operations that have been conducted for

decades, Matthew Ward Johnson’s proposed operation of the DJI Inspire 1 will not implicate any

privacy issues. Specifically, the DJI Inspire 1 will be operated only in compliance with operating 

documents (i.e. Aerial Operations Manual, Monthly Maintenance Log, and the DJI Inspire 1 

Instruction Manual's) which requires property owner involvement as well as local law 

enforcement notification, and in accordance with the Federal Aviation Regulations, including the 

minimum altitude requirements of 14 C.F. R. § 91.119.

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 Matthew Ward Johnson Seeks Exemption.

1. Reasons Why the DJI Inspire 1 Meets 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, Matthew Ward Johnson’s operation of the DJI Inspire 1

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 
19

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 rulemaking 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).

(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, Matthew Ward Johnson submits that the DJI Inspire 1 can operate 

safely in the NAS pursuant to FMRA Section 333, as demonstrated by: (a) the characteristics of 
20

the DJI Inspire 1; (b) the pilot certification requirement; and (c) the specific operating 

limitations.

a. The Specifications of the DJI Inspire 1 Demonstrate Its Safe Characteristics.

The DJI Inspire 1 does 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

The technical specifications of the DJI Inspire 1 are set forth by the DJI Inspire 1

Specifications and Data Sheet, attached hereto as Exhibit A.

ii. The DJI Inspire 1 Autonomous Flight And Navigation Modes Enable The UAS's To

Remain Within A Defined Operational Area.

The DJI Inspire 1 may be operated in both manual and fully autonomous flight modes. 

The DJI Inspire 1 may be operated in manual flight mode only. A complete description of the

flight and navigational modes of the DJI Inspire 1 is provided at pages 12-33 of the DJI Inspire 1 

User Manuals, attached hereto as Exhibit A.

Iii. The DJI Inspire 1 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 will remain stationary in flight, for 3

seconds or more. If, after 3 seconds, the DJI Inspire 1 does not reacquire control link data from

the GCS, 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 are set forth at pages 10 

through 17 of the DJI Inspire 1 User Manuals, attached hereto as Exhibit A.

iv. The DJI Inspire 1 GCS and Its Operation.
21

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

flight control software is provided at pages 12 through 43 of the DJI Inspire 1 User Manual. The 

DJI Inspire 1 User Manual is attached hereto as Exhibit A.

b. Flight Operations of DJI Inspire 1 Are Limited to the Line Of Sight of A Certificated 

Pilot in Command with A Safety Observer.

Matthew Ward Johnson will only utilize certificated pilots to act as a pilot in command 

(PIC) of the DJI Inspire 1. Additionally, a safety observer will assist all pilots during flight time.

c. Flights of DJI Inspire 1 Will Be Conducted Pursuant To Specific Operating Limitations.

In seeking this exemption, Matthew Ward Johnson proposes to commercially operate DJI

Inspire 1 for the special purpose of conducting aerial video and photography over certain areas of 

the 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 UAS's weighing less than 55 pounds maximum 

gross weight: DJI Inspire 1 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 UA may not be flown at an indicated airspeed exceeding 20 knots.

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.
22

5. The UA's 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 driver’s license.

6. The use of first person view (FPV) by the PIC or safety observer (SO) is not permitted.

7. 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 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.

8. 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.

9. 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 
23

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.

10. 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 Ground Control Station must be included in the 

preflight inspection. All maintenance and alterations must be properly documented in the aircraft 

records.

11. 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.

12. 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.

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

overhaul, replacement, inspection, and life limit requirements.

14. 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 
24

returning the UAS to service. Each UAS's 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 possess a private pilot certificate and at least a current third-class medical 

certificate or an operator’s certificate.

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 PIC's 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 5 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 
25

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 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.

21. If the UA loses communications or loses its GPS signal, it must return to a pre-determined

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 UAS 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

26. Before conducting operations the radio frequency spectrum used for operation and control of

the UAS 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 UAS must remain clear and yield the right of way to all manned aviation operations and

activities at all times.

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

30. 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:

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

UAS 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).
27

31. 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.

32. 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 Website: 

www.ntsb.gov.

2. Reasons Why an Exemption from The Requirements Of Section 61.113(a) And (b)

Would Not Adversely Affect Safety

Matthew Ward Johnson 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 

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 UAS in a manner consistent with the 

exemption, including evasive and emergency maneuvers and maintaining appropriate distances 

from people, vessels, vehicles and structures. Considering Matthew Ward Johnson’s proposed 

area of operations, and the operating limitations set forth-above; the parallel nature of private 

pilot aeronautical knowledge requirements to those of commercial pilot requirements (See 

Exemption No. 11062); and the airmanship skills necessary to safely operate the DJI Inspire 1 

UAS, Matthew Ward Johnson submits that the additional manned airmanship experience of a 

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

Matthew Ward Johnson '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 
28

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).

Matthew Ward Johnson will not allow any PIC to operate the DJI Inspire 1 UAS unless that PIC 

has demonstrated, by meeting minimum flight-hour requirements of the DJI Inspire 1 UAS 

training and currency requirements, that the PIC is able to safely operate the DJI Inspire 1 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 Matthew Ward Johnson’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 
29

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 flighthour 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, 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, Matthew Ward Johnson will ensure safe operations by not allowing any 

PIC to operate the DJI Inspire 1 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

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, Matthew Ward Johnson will ensure that the DJI Inspire 1 UAS is in an airworthy 

condition based upon the UAS’s compliance with its operating documents and as stated in the 
30

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 UAS's 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 

Matthew Ward Johnson’s operation of the DJI Inspire 1 UA's 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 on board the aircraft. Prior to each 

flight, a zero altitude initiation point is automatically established by the UAS's 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 14 C.F.R. 

Section 91.151(b) as a result of (1) the technical specifications of the DJI Inspire 1 UAS's; (2) 
31

the limitations on the proposed flight operations; and (3) the location of the proposed flight 

operations. 

Accordingly, Matthew Ward Johnson will ensure that he will safely operate the battery 

powered DJI Inspire 1 UA's during daylight hours in VFR conditions, with enough battery power 

to fly for a total duration of 15 minutes to the first point of intended landing and, assuming 

normal cruising speed, to fly after that for at least 3 minutes. Here, as in Exemption No. 11109, 

the technical specifications of the DJI Inspire 1 UAS's 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 DJI Inspire 1 UAS's provide audible and visual

warnings to the PIC at the GCS when the UA's 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 UAS's 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).
32

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, Matthew Ward Johnson 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 Matthew 

Ward Johnson will use trained technicians to perform maintenance, alterations, or preventive 

maintenance on the UAS's using the methods, techniques, and practices prescribed in the 

operating documents i.e., the Operations Manual, Monthly Maintenance Log, and DJI Inspire 1 

Instruction Manual. 

Furthermore, Matthew Ward Johnson will document and maintain all maintenance 

records for the DJI Inspire 1 UAS's. Since the DJI Inspire 1 UAS's will be inspected as 

prescribed by the operating documents, Matthew Ward Johnson 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 User Manuals is attached hereto as Exhibit B; a copy of the DJI Inspire 1 UAS 

Maintenance LOG is attached hereto as Exhibit C.

Likewise, the exemption sought will not adversely affect safety because Matthew Ward 

Johnson 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 UAS's will be performed by trained technicians. Maintenance will be documented and 

maintained utilizing the monthly maintenance log. Significantly, previous exemptions granted 
33

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 Matthew Ward Johnson’s proposed 

operating limitations, the operating documents, and the technical aspects of the DJI Inspire 1 

UAS's, Matthew Ward Johnson 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, Matthew Ward Johnson requests that

the FAA prescribe special conditions for the intended operation of DJI Inspire 1 UAS's, 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 UA's 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 
34

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 UAS's, 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 because of a novel or 

unusual design feature of the aircraft, aircraft engine or propeller, it may prescribe 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 Matthew Ward 

Johnson’s intended operation of the DJI Inspire 1 UAS's, 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 Matthew Ward Johnson Seeks Exemption:

Matthew Ward Johnson 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 Matthew Ward Johnson Seeks:
35

This exemption will permit Matthew Ward Johnson 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 Matthew 

Ward Johnson’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, Matthew Ward Johnson 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, Matthew Ward Johnson will operate the DJI Inspire 1 UAS safely in 

the NAS, without creating a hazard to users of the NAS, or the public, or otherwise pose a threat 

to national security.

CONCLUSION

As set forth herein, Matthew Ward Johnson 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 UAS's 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 
36

advancing the interests of the public, by allowing Matthew Ward Johnson to safely, efficiently,

and economically operate the DJI Inspire 1 UAS's commercially within the NAS.

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

Modernization and Reform Act of 2012, Section 333, Matthew Ward Johnson 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 Matthew Ward Johnson to operate the 

DJI Inspire 1 UAS commercially for the purpose of conducting aerial video and photography

over certain areas of the United States.

Dated: July 29, 2015

Respectfully submitted,

Matthew Ward Johnson
37

APPENDICES:

A - DJI Inspire 1 Specifications

B – DJI Inspire 1 – User Manual

C – DJI Inspire 1 - Monthly Maintenance Log

APPENDIX –A

DJI Inspire 1 TECHNICAL SPECIFICATIONS

Matthew Ward Johnson only utilizes safe and reliable UAS's. DJI is an industry leader in small

UAS production. DJI UAS's 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, Inspire 1 Radio Control Transmitter

Aircraft

Model T600

Weight (Battery Included) 2935 g

Hovering Accuracy (Gps Mode) Vertical: 0.5 m Horizontal: 2.5 m Max

Angular Velocity Pitch: 300°/s Yaw: 150°/s

Max Tilt Angle 35°

Max Ascent Speed 5 m/s

Max Descent Speed 4 m/s

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

Max Flight Altitude 4500 m

Max Wind Speed Resistance 10 m/s

Max Flight Time Approximately 18 minutes

Motor Model DJI 3510

Propeller Model DJI 1345

Indoor Hovering Enabled by default

Operating Temperature Range -10° to 40° C

Diagonal Distance 559 to 581 mm

Dimensions 438x451x301 mm

Gimbal

Model ZENMUSE X3

Output Power (With Camera) Static: 9 W

In Motion: 11 W Operating Current

Station: 750 mA Motion: 900 mA

Angular Vibration Range ±0.03°

Mounting Detachable

Controllable Range Pitch: -90° to +30° Pan: ±320°

Mechanical Range Pitch: -125° to +45° Pan: ±330°

Max Controllable Speed Pitch: 120°/s Pan: 180°/s

Camera

Name X3

Model FC350
38

Total Pixels 12.76M

Effective Pixels 12.4M

Image Max Size 4000x3000

Iso Range 100-3200 (video) 100-1600 (photo)

Electronic Shutter Speed 8s/ 1/8000s

Fov (Field Of View) 94°

Cmos Sony EXMOR 1/2.3”

Lens 

20mm (35mm format equivalent)f/2.8 focus at ∞ ) ; 9 Elements in 9 groups ; Anti-distortion ; 

Single shoot; Burst shooting: 3/5/7 frames

Still Photography Modes

Auto Exposure Bracketing (AEB): 3/5 bracketed frames at 0.7EV Bias; Time-lapse

Video Recording Modes UHD (4K): 4096x2160p24/25, 3840x2160p24/25/30FHD:

1920x1080p24/25/30/48/50/60

HD: 1280x720p24/25/30/48/50/60

Max Bitrate Of Video Storage 60 Mbps

Supported File Formats FAT32/exFAT ; Photo: JPEG, DNG

Video: MP4/MOV (MPEG-4 AVC/H.264)

Supported Sd Card Types Micro SD; Max capacity: 64 GB. Class 10 or UHS-1 rating required

Operating Temperature Range 0° to 40° C

Remote Controller

Name C1

Operating Frequency 922.7~927.7 MHz (Japan Only)

5.725~5.825 GHz

2.400~2.483 GHz

Transmitting Distance (Outdoor And Unobstructed) 2 km

Eirp 10dBm@900m, 13dBm@5.8G, 20dBm@2.4G

Video Output Port USB, mini-HDMI

Power Supply Built-in battery

Charging DJI charger

Dual User Capability Host-and-Slave connection

Mobile Device Holder Tablet or Phone

Max Mobile Device Width 170mm

Output Power 9 W

Operating Temperature Range -10° to 40° C

Storage Temperature Range Less than 3 months: -20° to 45° C

More than 3 months: 22° to 28° C

Charging Temperature Range 0-40° C

Battery 6000 mAh LiPo 2S
39

APPENDIX – B

DJI Inspire 1 – Manufacturer's User Manual

http://download.djiinnovations.com/downloads/inspire_1/en/Inspire_1_User_Manual_v1.2_en.pdf

http://www.dji.com/product/inspire-1/download

APPENDIX – C

Matthew Ward Johnson Monthly Maintenance and Repair Log

Aircraft: DJI Inspire 1, Model T600

Description/Maintenance

Conducted:

Repair/Maintenance

Performed By: 

Airframe

Batteries – discharge and recharge 

Motors

Propellers – replaced every month

Flight

Control

Update – perform firmware updates as released by DJI

Gimbal

Misc: -

Hours: 

Date:

Date Issue Discovered

Date Issue Resolved

Issue