UNITED STATES OF AMERICA

DEPARTMENT OF TRANSPORTATION

FEDERAL AVIATION ADMINISTRATION

WASHINGTON, DC

Regulatory Docket No. _______________

IN THE MATTER OF THE PETITION FOR EXEMPTION OF:

RENATO CORTABITARTE MARTÍN

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 DJI INSPIRE 1 UNMANNED

AIRCRAFT SYSTEMS

PURSUANT TO SECTION 333 OF

THE FAA MODERNIZATION AND REFORM ACT OF 2012

(PUBLIC LAW 112-95)

Submitted on July 22, 2015

Renato Cortabitarte Martín

C/ Sardenya, 386

080025 Barcelona - Spain

0034 609073997
TABLE OF CONTENTS

GLOSSARY OF

ABBREVIATIONS....................................................................................3

SUMMARY................................................................................................4

INTRODUCTION AND INTERESTS OF

PETITIONER..............................................................................................4

BACKGROUND........................................................................................5

BASIS FOR

PETITION...................................................................................................5

NAME AND ADDRESS OF 

PETITIONER..............................................................................................7

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

CORTABITARTE MARTÍN SEEKS 

EXEMPTION..............................................................................................7

THE EXTENT OF RELIEF RENATO CORTABITARTE MARTÍN

SEEKS AND THE REASON

RENATO CORTABITARTE MARTÍN SEEKS THE 

RELIEF...................................................................................................10

THE REASONS WHY GRANTING RENATO CORTABITARTE 

MARTÍN’S REQUEST

WOULD BE IN THE PUBLIC INTEREST ............................................12

THE REASONS WHY GRANTING THE EXEMPTION 

WOULD NOT ADVERSELY AFFECT

SAFETY....................................................................................................15

CONCLUSION.........................................................................................28
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)

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
SUMMARY

Renato Cortabitarte Martín 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 Renato Cortabitarte Martín to operate an Unmanned Aircraft 

System (UAS) for the commercial

purpose of conducting aerial video and photography of to be used in 

televisión commercials, weather traffic and news reports, and sporting 

events over certain areas of the United States.

INTRODUCTION AND INTERESTS OF THE PETITIONER

My name is Renato Cortabitarte Martín. I am 51 years old. My areas of 

interests include flying, filmmaking, and photography. I am actively 

involved as an independent cameraman and drone operator.

I Live in Spain and i have permission to opérate Rpas under the rules of 

AESA ( Agencia Española de Seguridad Aérea). I have Rpas Pilot License

by SENASA (ATO), medical certificate nivel II, and I have all the legal 

requeriments for fly RPAS for commercial uses in Spain.

The objective of my Aerial Video and Photography Services is to provide

high quality imaging for a variety of commercial and public uses, 

specifically targeting:

 Creation of commercial messages for Television and Film.

 Independent filmmaking.

 Coverage of Sporting events.

 Coverage of Special events.
BACKGROUND

Unmanned Aircraft Systems: DJI Inspire 1 UAS

Renato Cortabitarte Martín seeks an exemption to operate DJI systems for 

compensation or hire within the NAS. The DJI Inspire 1 are vertical takeoff

and landing (VTOL) Unmanned Aircraft (UA) with a Ground Control 

Station (GCS) utilizing electronic tablet or smart phone systems. 

The DJI Inspire 1 has a maximum gross weight of 6 pounds 7.5 ounces, a

length of 17.3 inches, width of 17.7 inches, height of 11.8 inches, and a 

maximum speed of approximately 42 knots. The DJI Inspire 1UAs are

equipped with four main rotors; driven by Lithium Polymer battery 

powered electric motors.

The DJI Inspire 1 UA that will be operated by Renato Cortabitarte Martín 

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, Renato Cortabitarte Martín, 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 

DJI Inspire 1 UAS 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).

In consideration of the speed, weight, size, and limited operating area 

associated

with the unmanned aircraft and its operation, Renato Cortabitarte Martín 

operation of DJI Inspire 1 UAS 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, Renato Cortabitarte Martín 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.

Renato Cortabitarte Martín submits that the requested relief is proper since 

an equivalent level of safety will be ensured. Renato Cortabitarte Martín 

will use experienced personnel or technicians to perform maintenance, 
alterations, or preventive maintenance on the usas using the methods, 

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

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

Furthermore, Renato Cortabitarte Martín will document and maintain all 

maintenance records for the DJI Inspire 1 UAS.

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

Private pilot privileges and limitations: Pilot in command, is requested by 

Renato Cortabitarte Martín 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 1 UAS in a manner consistent with

this exemption, including evasive and emergency maneuvers and 

maintaining appropriate distances from people, vessels, vehicles and 

structures.

Renato Cortabitarte Martín seeks relief from Section 91.7(a), entitled Civil 

aircraft airworthiness, because the DJI Inspire 1 UAS do not

require an airworthiness certificate in accordance with 14 C.F.R. Part 21, 

Subpart H. As such, Renato Cortabitarte Martín submits that he will ensure 

that the DJI Inspire 1 UAS are in an airworthy condition, prior to every 

flight, by determining that the UASs 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.

Renato Cortabitarte Martín also seeks an exemption from the requirements 

of Section 91.121, entitled Altimeter Settings, as the DJI Inspire 1 UA

will not have a typical barometric altimeter onboard. However, altitude 

information of the DJI Inspire 1UA will be provided to the PIC via Global

Positioning System (GPS) equipment and radio communications telemetry 

data link, which downlinks from the UA to the GCS for active monitoring 

of the flight path. This altitude information, combined with Renato 

Cortabitarte Martín’s operation of DJI Inspire 1 UAS within visual line of 

sight, at or below 500 feet AGL, will ensure a level of safety equivalent to 

Section 91.121.

Additionally, Renato Cortabitarte Martín seeks an exemption from the 

requirements of Section 91.151(b), entitled Fuel requirements for flight in 

VFR conditions. Renato Cortabitarte Martín submits that safety will not be 

affected by operation of the DJI Inspire 1 UA 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 13.5 

minutes to the first point of intended landing and,

assuming normal cruising speed, to fly after that for at least 4.5 minutes.

In accordance with 14 C.F.R. § 11.81, Renato Cortabitarte Martín 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:

Renato Cortabitarte Martín 

C/ Sardenya, 386

08025 Barcelona - Spain

0034 609073997

Email: rcortabitarte@yahoo.es

B. The Specific Sections Of 14 C.F.R. From Which Renato 

Cortabitarte Martín Seeks Exemption.

1. Renato Cortabitarte Martín 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. Renato Cortabitarte Martín 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. Renato Cortabitarte Martín Seeks Exemption From The 

Requirements Of Section 91.121.

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. Renato Cortabitarte Martín Seeks Exemption From The 

Requirements Of Section 91.151(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. Renato Cortabitarte Martín Seeks Exemption From The 

Requirement Of Section 91.405(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[.]

6. Renato Cortabitarte Martín 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. Renato Cortabitarte Martín 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. Renato Cortabitarte Martín 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:

(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.

(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 Renato Cortabitarte Martín Seeks And The 

Reason Renato Cortabitarte Martín Seeks The Relief.

1. Extent Of Relief Renato Cortabitarte Martín Seeks And The Reason 

Renato Cortabitarte Martín 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, Renato Cortabitarte Martín submits that an 

equivalent level of safety will be maintained because no PIC will be 

allowed to operate the DJI Inspire 1 UAS unless that PIC has met certain 

flight-hour and currency requirements, demonstrating that the PIC is able 

to safely operate either the DJI Inspire 1 UAS 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, Renato Cortabitarte Martín submits that all flights of the 

DJI Inspire 1 UAS, conducted by the PIC pursuant to the grant of this 

Petition: (1) will be incidental to Renato Cortabitarte Martín's business; and 

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

2. Extent Of Relief Renato Cortabitarte Martín Seeks And The Reason 

Renato Cortabitarte Martín Seeks Relief From Section 91.7(a).

Relief from Section 91.7(a) entitled Civil aircraft airworthiness, is 

requested to the extent required to allow Renato Cortabitarte Martín to 

determine that the DJI Inspire 1 UAS are in airworthy condition prior to 

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

documents (i.e., the Renato Cortabitarte Martín Aerial Operations Manual, 
Monthly Maintenance Log, and DJI Inspire 1 Instruction Manual).

Renato Cortabitarte Martín seeks the requested relief because the DJI 

Inspire 1 UAS do not require an airworthiness certificate in accordance 

with 14 C.F.R. Part 21, Subpart H. Therefore, Renato Cortabitarte Martín

will ensure that the DJI Inspire 1 UAS are 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 Renato Cortabitarte Martín Seeks And The Reason 

Renato Cortabitarte Martín 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, which utilize a

barometric pressure sensor, GPS 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),

Renato Cortabitarte Martín seeks the requested relief because the DJI

Inspire 1 UA’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 UA are 

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 Renato Cortabitarte Martín Seeks And The Reason 

Renato Cortabitarte Martín 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 UA during daylight hours in visual meteorological

conditions (VMC), under visual flight rules (VFR), for a total duration of 

13.5 minutes to the first point of intended landing and, assuming normal 

cruising speed, to fly after that for at least 4.5 minutes. Renato Cortabitarte 

Martín seeks the requested relief because without an exemption from 

Section 91.151(b), the flight time duration of the battery powered DJI

Inspire 1 UA will severely constrain the practicality of any

aerial video or still photo flight operations that Renato Cortabitarte Martín
proposes to conduct pursuant to this Petition.

Significantly, as set forth below, the technical specifications of the DJI 

Inspire 1 UAS, the DJI Inspire 1 operating documents, and Renato 

Cortabitarte Martín’ proposed operating limitations, ensure that Renato 

Cortabitarte Martín will safely operate the battery powered DJI Inspire 1

UA during daylight hours in visual meteorological conditions (VMC), 

under visual flight rules (VFR), with enough battery power to fly for a total 

duration of 13.5 minutes to the first point of intended landing and, 

assuming normal cruising speed, to fly after that for at least 4.5 minutes.

5. Extent Of Relief Renato Cortabitarte Martín Seeks And The Reason 

Renato Cortabitarte Martín 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, 

Renato Cortabitarte Martín requests relief from these Sections because the 

DJI Inspire 1 UAS do not require airworthiness certificates. As set forth 

more fully below, the DJI Inspire 1 UAS meet the conditions of FMRA 

Section 333 for operation without an airworthiness certificate. Accordingly, 

Renato Cortabitarte Martín will use trained technicians to perform 

maintenance, alterations, or preventive maintenance on the UAS

using the methods, techniques, and practices prescribed in the UAS 

operating documents (i.e., the Renato Cortabitarte Martín Aerial 

Operations Manual, Monthly Maintenance Log, and 

DJI Inspire 1 Instruction Manual). Furthermore, Renato Cortabitarte Martín

will document and maintain all maintenance records for the 

DJI Inspire 1 UAS.

D. The Reasons Why Granting Renato Cortabitarte Martín 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 

Renato Cortabitarte Martín to safely, efficiently, and economically perform 

aerial video and photography of construction sites, real estate, and 

landscape over certain areas of the United States.

Additionally, use of the DJI Inspire 1 UAS will decrease congestion of the 

NAS, reduce pollution, and provide significant benefits to the

economy. Notably, the benefits of Renato Cortabitarte Martín’ proposed 

operation of the DJI Inspire 1 UASs will be realized without implicating 

any privacy issues.

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

The DJI Inspire 1 UA are battery powered and serve 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 a 

DJI Inspire 1 UA 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 UA do 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 UAS.

Conducting aerial acquisitions with the DJI Inspire 1 UAS, 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 UAS produce 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 UA, while reducing the 

carbon footprint of aerial acquisitions, also eliminates noise pollution, as 

the UAs are propelled by battery powered electric motors, rather than an 

internal combustion engine.

By using the DJI Inspire 1 UAS 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 UA 

(weighing approximately 6 pounds 7.5 ounces, at their

maximum gross weights with lengths of 17.3 inches, widths of

17.7 inches, 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 wingspan of 

approximately 42 feet, a length of 34 feet, and a fuel capacity of 180 

gallons).
3. Performing Aerial Video and Photography Operations With The 

DJI Inspire 1 UAS Will Benefit The Economy.

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

economical alternative to using manned aircraft to conduct similar

aerial operations. As such, operation of the DJI Inspire 1 UAS will allow

United States based companies 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 UAS 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 UAS, companies can remain competitive 

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

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 UAS, 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, Renato Cortabitarte Martín’s proposed operation of the DJI 

Inspire 1 UAS will not implicate any privacy issues. Specifically, the 

DJI Inspire 1 UAS will be operated only in compliance with operating

documents (i.e., the Renato Cortabitarte Martín Aerial Operations Manual, 

Monthly Maintenance Log, and DJI Inspire 1 Instruction Manual) 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 

Renato Cortabitarte Martín Seeks Exemption.

1. Reasons Why The DJI Inspire 1 UA Meet 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, Renato 

Cortabitarte Martín’s operation of the DJI Inspire 1 UAS 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 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, Renato Cortabitarte Martín submits that the DJI 

Inspire 1 UAS can operate safely in the NAS pursuant to FMRA

Section 333, as demonstrated by: (a) the characteristics of the DJI Inspire 1 

UAS; (b) the pilot certification requirement; and (c) the specific

operating limitations.

a. The Specifications Of The DJI Inspire 1 UAS Demonstrate Its Safe 

Characteristics.

The DJI Inspire 1 UASs do 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 UAS.

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

DJI Inspire 1 Specifications and Data Sheet, attached hereto as Exhibit A 

and B.

ii. The DJI Inspire 1 UAS Autonomous Flight And Navigation 

Modes Enable The UASs To Remain Within A Defined 

Operational Area.

The DJI Inspire 1 UASs may be operated in both manual and fully 

autonomous flight modes. A complete description of the flight and

navigational modes of the DJI Inspire 1 UAS is provided at

pages 12-16 and 45-50 of the DJI Inspire 1 User Manuals, attached hereto 

as Exhibit C and D.

iii. The DJI Inspire 1 UASs 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 UA will remain stationary, 

in flight, for 3 seconds or more. If, after 3 seconds, the DJI Inspire 1 UA do 

not reacquire control link data from the GCS, the UA 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 at 

pages 13 through 15 of the DJI Inspire 1 User Manuals, attached hereto as 

Exhibit C and D.
iv. The Inspire 1 GCS And Its Operation.

A complete description of the operation and specifications of the 

DJI Inspire 1 GCS and flight control software is provided at pages 40 

through 47 of the

DJI Inspire 1 User Manual. DJI Inspire 1 User Manuals is

attached hereto as Exhibits C and D.

b. Flight Operations Of DJI Inspire 1 UAS Are Limited To The Line 

Of Sight Of A Certificated Pilot in Command With A Safety Observer.

Renato Cortabitarte Martín will only utilize certificated pilots who possess 

a current and valid airman medical certificate to act as a pilot in command 

(PIC) of the DJI Inspire 1 UAS. Additionally, a safety observer will assist 

all pilots during flight time.

c. Flights Of DJI Inspire 1 UAS Will Be Conducted Pursuant To 

Specific Operating Limitations.

In seeking this exemption, Renato Cortabitarte Martín proposes to 

commercially opérate DJI Inspire 1 UASs for the special purpose of 

conducting aerial video and photography over certain areas of 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 UASs

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 UAs may not be flown at an indicated airspeed exceeding 20 knots.

4. The UA must be operated at an altitude of no more than 500 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.

5. The UAs 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 FAAissued airman medical certificate.

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 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 equirements.

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 returning the UAS to service.

15. Each UASs operated under this exemption must comply with all 

manufacturer Safety Bulletins.

16. The authorized person must make an entry in the aircraft record of the

corrective action taken against discrepancies discovered between 

inspections.

17. The PIC must possess at least a private pilot certificate and at least a 

current third- class medical certificate.

18. The operator may not permit any PIC to operate unless the PIC meets 

the operator’s qualification criteria and demonstrates the ability to safely 

opérate 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 PICs 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.

19. 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.

20. 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 required by the 

operator’s COA. The letter of agreement with the airport management must 

be made available

to the Administrator upon request.

21. 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.
22. 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.

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

emergencies in accordance with the operating documents.

24. 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 UA with 25% 

battery power remaining.

25. 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.

26. 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.

27. Before conducting operations, the radio frequency spectrum used for

operation and control of the UA must comply with the Federal

Communications Commission (FCC) or other appropriate government

oversight agency requirements.

28. 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.

29. The UA must remain clear and yield the right of way to all manned 

aviation operations and activities at all times.

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

vehicle.

31. 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 UA and/or debris in the event of an

accident. The operator must ensure that nonparticipating persons

remain under such protection. If a situation arises where

nonparticipating persons leave such protection and are within 500 feet

of the UA, flight operations must cease immediately 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).

32. 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.

33. Any incident, accident, or flight operation that transgresses the lateral 

or vertical boundaries of the operational area as defined by the applicable 

COA must be reported to the FAA's UAS Integration Office (AFS-80) 

within 24 hours. Accidents must be reported to the National Transportation 

Safety Board (NTSB) per instructions contained on the NTSB Web site:

www.ntsb.gov.

2. Reasons Why An Exemption From The Requirements Of Section 

61.113(a) And (b) Would Not Adversely Affect Safety.

Renato Cortabitarte Martín 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 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.

Considering Renato Cortabitarte Martín’ 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, Renato Cortabitarte

Martín submits that the additional manned airmanship

experience of a commercially certificated pilot would not correlate to the 

airmanship skills necessary for Renato Cortabitarte Martín’ 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 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).

Renato Cortabitarte Martín will not allow any PIC to operate the DJI 
Inspire 1 UAS unless that PIC has demonstrated, by meeting minimum 

flight-hour requirements or 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 Renato Cortabitarte 

Martín’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 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, Renato Cortabitarte Martín 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, Renato Cortabitarte Martín 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 

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 UA

will be provided to the PIC via GPS equipment and a radio ommunications 

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 Renato Cortabitarte Martín’s operation of the DJI Inspire 1 

UAs within visual line of sight, at or below 500 feet AGL, will ensure a 

level of safety equivalent to Section 91.121. The altitude information will 

be generated by GPS equipment installed onboard the aircraft.

Prior to each flight, a zero altitude initiation point is automatically 

established by the UASs 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; (2) the limitations on the proposed 

flight operations; and (3) the location of the proposed flight operations. 

Accordingly, Renato Cortabitarte Martín will ensure that it will safely 

operate the battery powered DJI Inspire 1 UAs during daylight hours in 

VFR conditions, with enough battery power to fly for a total duration of 

13.5 minutes to the first point of intended landing and, assuming normal 

cruising speed, to fly after that for at least 4.5 minutes.

Here, as in Exemption No. 11109, the technical specifications of the 

DJI Inspire 1 UASs; 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 the Inspire 1 UAS provide audible and visual warnings to

the PIC at the GCS when the UAs 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 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).

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, Renato Cortabitarte Martín 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 Renato 

Cortabitarte Martín will use trained technicians to perform maintenance,

alterations, or preventive maintenance on the UASs using the methods, 
techniques, and practices prescribed in the operating documents (i.e., the 

Renato Cortabitarte Martín Aerial Operations Manual, Monthly 

Maintenance Log, and DJI Inspire 1 Instruction Manual). Furthermore, 

Renato Cortabitarte Martín will document and maintain all maintenance 

records for the DJI Inspire 1 UAS.

Since the DJI Inspire 1 UAS will be inspected as prescribed by the 

operating documents, Renato Cortabitarte Martín 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 are attached 

hereto as Exhibit C and D; a copy of the DJI Inspire 1 UAS Maintenance 

LOG is attached hereto as Exhibit E.

Likewise, the exemption sought will not adversely affect safety because 

Renato Cortabitarte Martín 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 will be performed by trained 

technicians.

Maintenance will be documented and maintained utilizing the monthly 

maintenance log.

Significantly, previous exemptions granted 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 Renato Cortabitarte Martín’ proposed operating 

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

Inspire 1 UAS, Renato Cortabitarte Martín 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, Renato 

Cortabitarte Martín requests that the FAA prescribe special conditions for 

the intended operation of the DJI Inspire 1 UAS, 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 UAs 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 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, 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, he prescribes 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 Leading Edge’s intended 

operation of the DJI Inspire 1 UAS, 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).

 A Summary That Can Be Published In The Federal Register, 

stating: The Rules From Which Renato Cortabitarte Martín Seeks 

Exemption:

Renato Cortabitarte Martín 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 Renato 
Cortabitarte Martín Seeks:

This exemption will permit Renato Cortabitarte Martín to commercially 

operate an Unmanned Aircraft System (UAS) for the purpose of 

conducting aerial video and photography over certain areas of the United 

States.

 Any Additional Information, Views, Or Arguments Available To 

Support

Renato Cortabitarte Martín’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, 

Renato Cortabitarte Martín’s 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, Renato Cortabitarte Martín 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, Renato Cortabitarte Martín 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 usas 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 advancing the interests 

of the public, by allowing Renato Cortabitarte Martín to safely, efficiently, 

and economically operate the DJI Inspire 1 UAS commercially within the 

NAS.

WHEREFORE, in accordance with the Federal Aviation Regulations and 

the FAA Modernization and Reform Act of 2012, Section 333, Renato 

Cortabitarte Martín 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 Leading Edge 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 22, 2015

 Respectfully submitted,

 Renato Cortabitarte Martín 

 

Renato Cortabitarte Martín

C/Sardenya, 386

08025 Barcelona – Spain
0034 609073997

APPENDIX – A

DJI INSPIRE 1 TECHNICAL SPECIFICATIONS

DJI is an industry leader in small UAS production. DJI UASs 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 (smart phone/Tablet devices)

2.2 DJI Inspire 1

2.2.1 Aircraft

2.2.1.1 Model – T600

2.2.1.2 Weight (Battery Included) – 6lbs 7.5291oz (2935g)

2.2.1.3 Hovering Accuracy (GPS Mode) – Vertical: 0.5m; Horizontal: 2.5m

2.2.1.4 Max Angular Velocity – Pitch: 300/s; Yaw: 150/s

2.2.1.5 Max Tilt Angle - 35

2.2.1.6 Max Ascent Speed – 5m/s

2.2.1.7 Max Descent Speed – 4m/s

2.2.1.8 Max Speed – 22m/s (ATTI mode, no wind – NOT 

RECOMMENDED)

2.2.1.9 Max Flight Altitude – 4500m

2.2.1.10 Max Wind Resistance – 10m/s

2.2.1.11 Max Flight Time – Approximately 18 minutes

2.2.1.12 Motor Model – DJI 3510

2.2.1.13 Propeller Model – DJI 1345

2.2.1.14 Operating Temperature Range – 14F to 104F (-10C to 

40C)

2.2.1.15 Dimensions – 17 1⁄4” x 17 3⁄4” x 12”

2.2.2 Gimbal

2.2.2.1 Model – ZENMUSE X3

2.2.2.2 Output Power (with camera) – Static: 9W; In Motion: 11W

2.2.2.3 Operating Current – Static: 750mA; In Motion: 900mA

2.2.2.4 Angular Vibration Range - ±0.03

2.2.2.5 Mounting – Detachable

2.2.2.6 Controllable Range – Pitch: -90 to +30; Pan: ±320

2.2.2.7 Mechanical Range – Pitch: -125 to 45; Pan: ±330

2.2.2.8 Max Controllable Speed – Pitch: 120/s; Pan: 180/s

2.2.3 Camera

2.2.3.1 Name – X3
2.2.3.2 Model – FC350

2.2.3.3 Total Pixels – 12.76M

2.2.3.4 Effective Pixels – 12.4M

2.2.3.5 Image Max Size – 4000x3000

2.2.3.6 ISO Range – 100-3200

2.2.3.7 Field of View - 94

2.2.3.8 CMOS – Sony EXMOR 1/2.3”

2.2.3.9 HD Video Recording – UHD(4K): 4096x2160p24/25,

3840x2160p24/25/30; FHD: 1920x1080p24/25/30/48/50/60; HD:

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

2.2.3.10 Operating Temperature Range - 32F - 104F (0C - 40C)

2.2.4 Transmitter

2.2.4.1 Name – C1

2.2.4.2 Operating Frequency – 5.728-5.850GHz; 2.400-2.483GHz

2.2.4.3 Communicating Distance (unobstructed) – 2000m

2.2.4.4 Output Power – 9W

2.2.4.5 Operating Temperature Range