U.S. Department of Transportation 

Docket Management System

1200 New Jersey Ave.,

S E Washington, DC 20590 

Peter J. Greer

Miles of Grace L.L.C.

10607 Direct River Drive

Coon Rapids, MN 55433

(612)723-1031

peter.greer@milesofgrace.net

CURRENT PETITION FOR EXEMPTION 333

I, PETER J. GREER, submit the following: 

Summary of request:

I am submitting this petition pursuant to the FAA Modernization and Reform Act of 2012 

and the procedures contained within 14 C.F.R. 11, so that I may operate the DJI Inspire 

1 quadcopter unmanned aircraft system (UAS) for the limited purpose of conducting 

aerial photography and videography below 400 feet AGL and further than 5 miles from 

any airport or heliport, in order to safely and legally capture aerial photography and 

videography.

In comparison, Exemption No. 11192 (which is essentially identical to my request), an 

exemption was approved for an individual with a Commercial Pilots license. I currently 

hold an Airline Transport Pilot certificate, as well as a current CFI/MEI. Aerial 

photography and videography operations for private and/or commercial properties and 

businesses benefit the public with enhanced perspectives of characteristics, amenities, 

and benefits a property has that cannot be displayed through ground level photography 

and videography. While this is essentially the same request as the one granted under 

Exemption No. 11977 / Regulatory Docket No. FAA–2015–1478, my request goes 

further, in that I hold an ATP.

Thank you for your time and attention to my request. 

Yours truly, 

Peter J. Greer
Sections from which exemptions are sought: 

a. FAA Modernization and Reform Act of 2012, PL 112-95 FEB. 14, 2012, Section 

333 

b. 14 CFR Part 21, subpart H 

c. 14 CFR Part 61.113(a) and (b) 

d. 14 CFT Part 91: 

i. 91.103(b)(2) 

ii. 91.105 

iii. 91.109 

iv. 91.119 

v. 91.121 

vi. 91.151 

vii. 91.405 

viii. 91.407 

ix. 91.409 

x. 91.417 

Public benefit: 

Use of sUAS technology to obtain imagery, information and data currently obtained by 

use of manned flight or manual methods: 

i. Reduces statistical risk to human life due to manned aircraft accidents (e.g., power 

line inspections) and due to other dangerous activities that can be avoided (e.g., 

 scaffolding/rigging failures during stack or bridge inspections). 

ii. Reduces the cost of obtaining such information, which benefits consumers and the 

 economy. 

iii. Reduces environmental impact by eliminating sources of hydrocarbon emissions 

from manned aircraft. 

All flight operations will comply with the following: 

 i. The manufacturers' Aircraft Flight Manuals and Operation Guidelines 

ii. Conducted in VMC conditions during daylight hours. 

iii. PIC and VO will maintain VLOS at all times. 

 iv. Pre-flight inspections (including ground control station) and a 

safety risk assessments will be conducted prior to each flight. 

v. Flight altitudes will remain below 400 feet above ground level. 

vi. Flight ground speeds will not exceed 40 knots. 

vii. Not intrude into Class B, C or D airspace, or published approach, 

SID or STAR, or take place within 5 nautical miles of an airport. 

viii. Not be made near persons as required in 14 CFR 91.119 and not over 

persons on the ground without their prior permission. 

ix. Each flight will be logged in both the PIC's logbook and the aircraft 

logbook. 
x. Not exceed 80% of the battery capacity of the aircraft, or 30 minutes, 

whichever occurs first. 

xi. Any incidents will be reported to NTSB within 24 hours of occurrence. 

xii. Miles of Grace L.L.C will maintain liability insurance of at least 

$1,000,000 issued by a major aviation insurance underwriter.

xiii. Any applicable local FSDO requirements. 

xiv. All other applicable regulations concerned with the operation of 

aircraft. 

THE UNMANNED AIRCRAFT (UA)

DJI Inspire 1 

• Professional grade

• Under 15 pounds takeoff weight

• 4 motors

• 15 to 20 minute flight time depending on battery size 

• Aircraft will use 2.4 GHz for control of the aircraft, and for sending data 

 with defined and tested lost link procedures

• On board stabilization/GPS/autopilot

I am petitioning for exemption to allow Miles of Grace L.L.C. to operate a DJI Inspire 1 

equipped with-a three-axis gimbals and using a onboard High-Def camera. This UA 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 operator and to exclude it from Class B, C and D airspace 

including a no-fly zone feature. The Inspire 1 also has the fail-safe function of the 

autopilot system, which means if the communication between the Main Controller and 

the transmitter is disconnected, the DJI Inspire 1 is automatically commanded by its 

onboard solid-state electronics to return to the takeoff point. If battery reaches a critical 

level, the aircraft will descend and land at the current location. Control of the aircraft is 

maintained during descent to allow the PIC to guide it to a safe landing. 

GROUND CREW 

• Pilot in Command (PIC). The pilot in command will have at minimum a private pilot 

license and a valid third class medical. 

• Camera Operator (optional). The Camera operator controls the camera onboard the 

aircraft for photography and videography missions. 

• Visual Observer (VO). The visual observer will provide additional situational 

awareness during flight operations. 
OPERATIONAL PARAMETERS 

1) The UAS will weigh less than 40 pounds. 

2) Flights will be operated within visual line of sight of a pilot and/or observer. 

3) Maximum total flight time for each operational flight will be approximately 15 

minutes. Flights will be terminated at 20% battery power.

4) Flights will be operated at an altitude of no more than 400 feet (91.4 meters) 

AGL. Unless a specific COA is obtained, the limit will be according to the 

“blanket” COA of 200 feet (61 meters). Typical operations are at or below the tree 

canopy level and within the bounds of the owner’s property. 

5) UAS pilot will be an FAA licensed airman with at least a private pilot’s certificate 

and third class medical. PIC will have completed operator and safety training 

from Miles of Grace L.L.C. PIC will also have accumulated and logged at least 30

hours total time as a UAS rotorcraft pilot including at least 15 hours logged as a 

UAS pilot with a multi-rotor UAS and 5 hours in the same make and model of 

UAS proposed under this exemption request. 

6) Permission will be obtained from the property owner. 

7) Pilot and observer will be able to communicate by voice at all times during the 

operation. 

8) The UAS will only be operated during daytime hours in VFR weather conditions. 

9) Operations may not be conducted aboard a moving device or vehicle. 

10) Maximum speed 40 knots. 

PRE-FLIGHT CHECKLIST 

High reflective vest (orange or green) worn at all times by entire ground crew

1) Weather conditions are suitable for VFR flight and wind is 20 knots or less. 

2) Measure battery voltage to make sure batteries are sufficiently charged before 

takeoff. 

3) Verify that all wiring connections are tight. 

4) Inspect rotor arms for cracks, damage, and loose hardware. 

5) Check to make sure propellers are secure and free from dirt, cracks and chips. 

6) Install main battery 

7) Verify all switch positions on the RC transmitters. 

8) Turn on radio control transmitters and video equipment. 

9) Ensure current firmware

10) Calibrate compass in accordance with DJI manual

11) Calibrate IMU’s in accordance with DJI manual

12) Do not initiate takeoff with a lock of less than 6 satellites.

13) Announce your intention to take off by announcing “Take Off”. 

Maintenance specific 

The current regulations require that an aircraft operator or owner “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...,” and others shall inspect or maintain the aircraft 

in compliance with part 43. 

 Given that the sections and Part 43 apply only to aircraft with an airworthiness 

certificate, these sections will not apply to the Petitioner. Maintenance will be 

accomplished by the operator pursuant to the DJI Inspire 1 Owner’s Manuals. An 

equivalent level of safety will be achieved because these small UAS are very limited in 

size and will carry a small payload and operate only in restricted areas for limited 

periods of time. If mechanical issues arise, the UAS can land immediately. The P.I.C.

will ensure that the UAS is in working order prior to initial flight, perform required 

maintenance and keep a log of any maintenance performed. The FAA issued exemption 

to these regulations in Exemption No. 11062, &11977. 

Conclusion 

As pointed out in this application, the SUAs 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 300 feet above the ground and 

outside 5 miles from any airport, heliport, seaplane 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 

assurances on the airworthiness of SUAs such as ours. 

For the reasons given above, the exemptions requested herein should be granted and 

Miles Of Grace L.L.C should be permitted to conduct small UAS 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. 

Respectfully Submitted, 

Peter J. Greer

Miles of Grace L.L.C.

10607 Direct River Drive 

Coon Rapids, MN 55433