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

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Submitted on July 29, 2015 Matthew Ward Johnson 9 Maple Springs Ct

. Columbia, SC 29223 803

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- 12472 TABLE OF CONTENTS Page GLOSSARY OF ABBREVIATIONS 3 SU MMARY 4 INTRODUCTION AND INTERESTS OF PETITIONER 4 BACKGROUND 5 BASIS FOR PETI TION 5

NAME AND ADDRESS OF PETITIONER 8 THE SPECIFIC SECTIONS OF 14 C.F.R. F ROM WHICH Matthew Ward Johnson SEEKS EXEMPTION 8

THE EXTENT OF RELIEF Matthew Ward Johnson SEEKS AND THE REASON Matthew Ward Johnson SEEKS THE RELIE F 12

THE REASONS WHY GRANTING Matthew Ward Johnson ’s REQUEST WOULD B E IN THE PUBLIC INTEREST 15

THE REASONS WHY GRANTING THE EXEMPTION WOULD NOT ADVERSELY AFFECT SAFETY 18

SUMMARY THAT CAN BE PUBLISHED IN THE FE DERAL REGISTER 3 4
ANY ADDITIONAL INFORMATION, VIEWS, OR ARGUMENTS AVAILABLE TO SUPPORT Matthew Johnson’s R EQUEST 3 5

CONCLUSION 3 5

APPENDICES 373 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 Si te
VMC Visual Meteorological Conditions
VTOL Vertical Takeoff and Landing4 SUMMARY

Matthew W ard 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 use s

. Matthew Ward Johnson

has over 10 years of experience in photographic and video t echnology with over 5 years
recreational and hobby experience in all aspects of aerial video and photo graphy. 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 m arketing
Aerial acquisitions used for land surveying
Aerial photography and video for commercial and residential projects
Aerial acquisitions used for inspections o f public and private structures5 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 a pproximately
2935g. W ithout the propellers attached it has a length of 17 .3 inches, height of 11.8 inches and

width of 1 7. 7 inches . The Inspire 1 uses 3510 motors and 1345 propellers and can achieve a
maximum speed of a pproximately 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 req uirements 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 unmanned6 aircraft and i ts 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 requ ests 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 re quested 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 hi gher 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. Matt hew Ward Johnson has achieved over

100+ hours of hobby, recreational operation with v a r i o u s U A S s i n c l u d i n g 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 emergen cy 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 do es 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 to tal duration of approximately 18 minutes w ith 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 W ard 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

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- 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)

a nd (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 empl oyment 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 91.121.9 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, w hen 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 sec tion, 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. Matth ew 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 R equirement 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[.]10 6. Matthew Ward Johnson Seeks Exemption From The Requirements Of Section

91.407(a)(1)

Section 91.407, entitle d 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:11 (1) Records of the maintenance, preventive maintenance, and alteration and records of the 100

- hour, annual, progressive, and other required or approved inspections, as appropriat e, 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 c ompletion 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) Copi es 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 retaine d 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 t o 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 co mpensation 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 that13 PIC has met certain flight

- hour and current requi rements, 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;

an d (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 Insp ire 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 i n 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 i n 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, GPS14 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 req uires 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), un der 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 exem ption 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 Petitio n.
Significantly, as set forth below, the technical specifications of the DJI Inspire 115 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 t o fly for a total duration of 15 minutes to the first point of intended land ing 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, M atthew 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 Unite d 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 reali zed 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 in crease 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 redu cing 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 co nscious 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 reduc ing the carbon17 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 subs tantial 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 t he 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 sim ilar
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 th e 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 t o 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 tradit ional

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 and18 contractors, which will ultimately contribute to growth o f 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

Instr uction 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 Granti ng 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 Meet s 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 con sidering whether a19 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 subt itle, 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 requiremen ts 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 chara cteristics of20 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 I nspire 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 Limitat ions.
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 l imitations:
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 f lown 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, a s 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 sati sfy 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 t he 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 av ailable 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 e xemption 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 revisio ns 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 o r revision would affect the basis upon which the FAA23 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 revision s 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 oper ating 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

do cuments.
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 person24 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, t raining 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 fli ght 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 referen ce 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 as25 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 u npredicted 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 intende d 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 inc luding 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

- Numb er) 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 docu ments 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 P IC 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. Barrier s 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 nonparti cipating 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 h as 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)

Wo uld 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 main taining 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 require ments 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 a ll material28 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 operat e 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 o f 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 takeoff s 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

includin g 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 529 hours as a UAS pilot operating the same make and model of UAS to be used for oper ations 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 flight

hour 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
regulatio ns 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 PI C 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 dist ances 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 the30 conditions and limitations herein. Additionally, the F AA 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, 11 150, 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 inform ation, 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 Sect ion 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 enou gh battery power

t o 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 Inspi re 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 pro vide 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 b attery 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

Sec tion 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 techn icians 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, Matth ew 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 att ached 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, an d practices prescribed by the
operating documents.
Furthermore, the exemption sought would maintain an equivalent level of safety

e stablished by Sections 91.407, 91.417(a) and 91.417(b), because all maintenance of the DJI
Inspire 1 UAS's will be perform ed by trained technicians. Maintenance will be documented and
maintained utilizing the monthly maintenance log. Significantly, previous exemptions granted33 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 a spects 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 grant ed 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 1 4 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 operation34 of the UAS in the NAS. Likewise, the Administrator may prescribe special conditions pu rsuant

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

unusu al 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 requiremen ts 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 detai l 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 a n 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 con ducting 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 also36 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 an d 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),

91.40 9(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 Johnson37 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 b e 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 Controllab le 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 FC35038 Total Pixels 12.76M Effective Pixels 12.4M Image Max Size 4000x3000 Iso Range 100

- 3200 (vid eo) 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 Op erating 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 2S39 APPENDIX

– B DJI Inspire 1

– Manufacturer's User Manual
http://download.dji

i nnovations.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