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UNITED STATES OF AMERICA

DEPARTMENT OF TRANSPORTATION

FEDERAL AVIATION ADMINISTRATION

WASHINGTON, DC

Regulator Docket No. ______________

IN THE MATTER OF THE PETITION FOR EXEMPTION OF: 

Smooth Shot, 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 UNMANNED AIRCRAFT 

PURSUANT TO SECTION 333 OF 

THE FAA MODERNIZAION AND REFORM ACT OF 2012 

(PUBLIC LAW 112-95) 

Submitted on July 30, 2015

Smooth Shot, LLC

9131 Blanco Dr

Lantana, TX 76226

Tel: 469-236-2005
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TABLE OF CONTENTS

GLOSSARY OF ABBREVIATIONS.............................................................................................3 

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

INTRODUCTION AND INTEREST OF THE PETITIONER.......................................................4 

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

BASIS FOR PETITION..................................................................................................................5 

CONCLUSION..............................................................................................................................22

APPENDIX A................................................................................................................................24

APPENDIX B................................................................................................................................26

APPENDIX C................................................................................................................................27
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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 

RPA Remotely Piloted Aircraft 

Section 333 FAA Modernization and Reform Act of 2012 (FMRA) Section 333 

SO Safety Observer 

SOP Standard Operating Procedures 

UA Unmanned Aircraft 

UAS Unmanned Aircraft System 

VFR Visual Flight Rules 

VLOS Visual Line of Site 

VMC Visual Meteorological Conditions 

VTOL Vertical Takeoff and Landing 
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SUMMARY

Smooth Shot, LLC 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 (UAS) pursuant to Section 333 of the FAA 

Modernization and Reform Act of 2012 (FMRA). 

This exemption will permit Smooth Shot, LLC to operate a Remotely Piloted Aircraft (RPA) or 

UAS for the commercial purpose of conducting aerial video and photography of construction 

sites, real estate property, search and rescue, and natural landscapes in the United States. 

INTRODUCTION AND INTEREST OF THE PETITIONER

Smooth Shot, LLC is owned and operated by Alex Boling and Jeremy Sweat located in Dallas, 

TX, and was founded in 2015 for the sole purpose of leveraging a UAS for capturing high 

quality aerial video, photographs, and raw data for commercial use, after successfully being 

exempt from the aforementioned requirements pursuant to Section 333 of the FAA FMRA.

The objective of Smooth Shot LLC is to provide quality imagery for a variety of commercial and 

public uses, specifically: 

 Real Estate videography and photography

 Construction sites before and after

 Research and Development

 Search and Rescue operations
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BACKGROUND

Unmanned Aircraft Systems: DJI Inspire 1

Smooth Shot, LLC seeks an exemption to operate DJI systems for compensation or hire within 

the United States National Airspace System. 

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

Ground Control Station (GCS) utilizing an electronic tablet and/or smart phone system. The 

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 1 UA is also equipped with 4 main rotors; driven by Lithium Polymer battery powered 

electric motors.

Two (2) DJI Inspire 1s that will be operated by Smooth Shot, LLC 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, Smooth Shot, LLC, 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 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, Smooth Shot, LLC’s operation of DJI Inspire 1 UASs 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, Smooth Shot, LLC 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. 

Smooth Shot, LLC submits that the requested relief is proper, as an equivalent level of safety 

will be ensured. Smooth Shot, LLC will ensure all safety and maintenance procedures outline by 

the UAS manufacture are complied with. Only authorized personnel or technicians will perform 

maintenance on the UASs using the methods, techniques, and practices prescribed in the 

operating documents provided by the UAS manufacture. All maintenance will be logged in the 

UAS maintenance record maintained by Smooth Shot, LLC. 

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

and limitations: Pilot in command, is requested by Smooth Shot, LLC to the extent necessary to 
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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. 

Smooth Shot, LLC seeks relief from Section 91.7(a), entitled Civil aircraft airworthiness, 

because the DJI Inspire 1 UAS does not require an airworthiness certificate in accordance with 

14 C.F.R. Part 21, Subpart H. As such, Smooth Shot, LLC submits that all maintenance and care 

will be conducted to will ensure the DJI Inspire 1 UAS is in an airworthy condition, prior to 

every flight, by determining that the UASs are in compliance with the operating documents 

provided by the UAS manufacture, and that the aircraft are in a condition for safe flight. 

Smooth Shot, LLC 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 aircraft barometric altimeter 

onboard. However, altitude information of the DJI Inspire 1 UA 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 Smooth Shot, LLC’s operation of the DJI Inspire 1 UAS within 

Visual Line of Sight, at or below 200 feet AGL, with the majority of flights at or below 100 feet 

AGL, will ensure a level of safety equivalent to Section 91.121.

Additionally, Smooth Shot, LLC seeks an exemption from the requirements of Section 

91.151(b), entitled Fuel requirements for flight in VFR conditions. Smooth Shot, LLC submits 

that granting an exemption will reduce current risk levels, as there is reliance on combustible fuel 

for the operation of the DJI Inspire 1 UA during daylight hours in visual meteorological 

conditions (VMC) under visual flight rules (VFR) will ensure the UA is operated in a safe 

manner compliant with applicable regulations. 

In accordance with 14 C.F.R. § 11.81, Smooth Shot, LLC 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: 

Smooth Shot, LLC

9131 Blanco Dr

Lantana, TX 76226

Tel: 469-236-2005

Email: SmoothShotLLC@gmail.com
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B. The Specific Sections Of 14 C.F.R. From Which Smooth Shot, LLC Seeks Exemption. 

1) Smooth Shot, LLC 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) Smooth Shot, LLC 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) Smooth Shot, LLC 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) Smooth Shot, LLC Seeks Exemption From The Requirements Of Section 

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

b. States the following

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) Smooth Shot, LLC 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 10 of this section, have 

discrepancies repaired as prescribed in part 43 of this chapter[.] 

6) 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) Smooth Shot, LLC 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) Smooth Shot, LLC Seeks Exemption From The Requirements Of Sections 

91.417(a) And 91.417(b).

Section 91.417, entitled Maintenance records, subsections (a) and (b), state the 

following: 

(a) Except for work performed in accordance with §§ 91.411 and 91.413, each registered owner 

or operator shall keep the following records for the periods specified in paragraph (b) of this 

section:
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(1) Records of the maintenance, preventive maintenance, and alteration and records of 

the 100-hour, annual, progressive, and other required or approved inspections, as 

appropriate, for each aircraft (including the airframe) and each engine, propeller, rotor, 

and appliance of an aircraft. The records must include—

(i) A description (or reference to data acceptable to the Administrator) of the 

work performed; and 

(ii) The date of completion of the work performed; and 

(iii) The signature, and certificate number of the person approving the aircraft for 

return to service. 

(2) Records containing the following information: 

i The total time in service of the airframe, each engine, each propeller, and each 

rotor. 9 

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 Smooth Shot, LLC Seeks And The Reason Smooth Shot, LLC Seeks The 

Relief. 
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1. Extent Of Relief Smooth Shot, LLC Seeks And The Reason Smooth Shot, LLC 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, Smooth Shot, LLC submits that an equivalent level of safety will 

be maintained because no PIC will be allowed to operate the DJI Inspire 1 UA unless that PIC has 

met certain flight-hour and currency requirements, demonstrating that the PIC is able to safely 

operate the DJI Inspire 1 UA 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, Smooth Shot, LLC submits that all flights of the DJI Inspire 1 UASs, conducted by the 

PIC pursuant to the grant of this Petition: (1) will be incidental to Smooth Shot, LLC business; 

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

2. Extent Of Relief Smooth Shot, LLC Seeks And The Reason Smooth Shot, LLC 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 Smooth Shot, LLC 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 Smooth Shot, LLC Aerial Operations Manual, Monthly Maintenance Log, 

and DJI Inspire 1 Instruction Manual). 

Smooth Shot, LLC 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, Smooth 

Shot, LLC 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 Smooth Shot, LLC Seeks And The Reason Smooth Shot, LLC 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), Smooth Shot, LLC 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. 
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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 Smooth Shot, LLC Seeks And The Reason Smooth Shot, LLC 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. Smooth Shot, LLC seeks the requested relief 

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

Inspire 1 UA will severely constrain the practicality of any aerial video or still photo flight 

operations that Smooth Shot, LLC proposes to conduct pursuant to this Petition. 

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

Inspire 1 operating documents, and Smooth Shot, LLC proposed operating limitations, ensure that 

Smooth Shot, LLC 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 Smooth Shot, LLC Seeks And The Reason Smooth Shot, LLC 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, Smooth Shot, LLC requests relief from these Sections 

because the DJI Inspire 1 UAS do not require airworthiness certificates. As set forth more fully 

below, DJI Inspire 1 UAS meet the conditions of FMRA Section 333 for operation without an 

airworthiness certificate. Accordingly, Smooth Shot, LLC will use trained technicians to perform 

maintenance, alterations, or preventive maintenance on the UASs using the methods, techniques, 

and practices prescribed in the UAS operating documents 12 (i.e., the Smooth Shot, LLC Aerial 

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

Smooth Shot, LLC will document and maintain all maintenance records for DJI Inspire 1 UAS. 

D. The Reasons Why Granting Smooth Shot, LLC 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 Smooth Shot, LLC to safely, 

efficiently, and economically perform aerial video and photography for wedding films, real estate, special 

events, film sets, 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 Smooth Shot, LLC proposed 

operation of DJI Inspire 1 UAS 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 
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amount of manned aircraft needed to perform aerial acquisitions, an exemption allowing the use 

of a DJI Inspire 1 UAS 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 

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 UAS. 

Conducting aerial acquisitions with 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 it’s maximum gross weight with a length of 17.3 inches, width 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, like Smooth Shot, LLC, 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 such as Smooth Shot, LLC, 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. 
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4. There Are No Privacy Issues. 

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

Smooth Shot, LLC, LLC 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 Smooth Shot, LLC, LLC Aerial Operations Manual, Monthly 

Maintenance Log, 14 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 Smooth Shot, LLC 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, Smooth Shot, LLC 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, Smooth Shot, LLC 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. 
14

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

Characteristics. 

The DJI Inspire 1 UAS 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 Appendix A. 

ii. The Inspire 1 UAS Autonomous Flight And Navigation Modes Enable 

The UAS To Remain Within A Defined Operational Area.

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

flight modes. A complete description of the flight and navigational modes of the 

Inspire 1 UAS is provided at pages 45-50 of the DJI Inspire 1 User Manual, 

attached hereto as Appendix B. 

iii. The DJI Inspire 1 UAS 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 is set forth 

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

Appendix B. 

iv. The DJI 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. The DJI Inspire 1 User Manual is attached hereto as 

Appendix B. 

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. 

Smooth Shot, LLC 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, Smooth Shot, LLC proposes to commercially operate DJI 

Inspire 1 UAS 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 
15

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 UA must be operated within visual line of sight (VLOS) of the PIC at all times. 

This requires the PIC to be able to use human vision unaided by any device other than 

corrective lenses, as specified on the PIC’s FAA-issued airman medical certificate. 

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. 
16

11. Any UAS that has undergone maintenance or alterations that affect the UAS 

operation or flight characteristics, e.g. replacement of a flight critical component, must 

undergo a functional test flight. The PIC who conducts the functional test flight must 

make an entry in the aircraft records. 

12. The pre-flight inspection must account for all potential discrepancies, e.g. inoperable 

components, items, or equipment, not already covered in the relevant sections of the 

operating documents. 

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

overhaul, replacement, inspection, and life limit requirements. 

14. The operator must carry out its maintenance, inspections, and record keeping 

requirements, in accordance with the operating documents. Maintenance, inspection, 

alterations, and status of replacement/overhaul component parts must be noted in the 

aircraft records, including total time in service, description of work accomplished, and 

the signature of the authorized person 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 thirdclass 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 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 

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. 
17

22. If the UA loses communications or loses its GPS signal, it must return to a 

predetermined 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 (NNumber) 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; 20 

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). 
18

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. 

Smooth Shot, LLC 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 Smooth Shot, LLC 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, Smooth Shot, 

LLC, LLC submits that the additional manned airmanship experience of a commercially 

certificated pilot would not correlate to the airmanship skills necessary for Smooth Shot, 

LLC, LLC 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). 

Smooth Shot, LLC 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 21 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 Smooth Shot, LLC 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: 
19

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 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 

regulations would satisfy this requirement. Training, proficiency, and experiencebuilding flights can also be conducted under the grant of exemption to 

accomplish the required flight time. During training, proficiency, and experiencebuilding 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, Smooth Shot, LLC 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 

nspire 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, Smooth Shot, LLC 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 communications telemetry data link, which downlinks from the 

UA to the GCS for active monitoring of the flight path and altitude. This altitude 

information, combined with Smooth Shot, LLC operation of the Inspire 1 UA within 

visual line of sight, at or below 500 feet AGL, will ensure a level of safety equivalent to 
20

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, Smooth Shot, LLC will ensure that it will safely 

operate the battery powered DJI Inspire 1 UA 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 UAS; 

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 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 UASs 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, Smooth Shot, LLC 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 Smooth Shot, LLC 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 Smooth Shot, LLC Aerial 

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

Furthermore, Smooth Shot, LLC will document and maintain all maintenance records for 

the DJI Inspire 1 UAS. 
21

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

Smooth Shot, LLC 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 Manual is

attached hereto as Appendix B; a copy of the DJI Inspire 1 UAS Maintenance LOG is 

attached hereto as Appendix C. 

Likewise, the exemption sought will not adversely affect safety because Smooth Shot, 

LLC 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 Smooth Shot, LLC proposed operating limitations, the operating 

documents, and the technical aspects of the DJI Inspire 1 UAS, Smooth Shot, LLC

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, Smooth Shot, LLC requests 

that the FAA prescribe special conditions for the intended operation of 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 
22

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 Smooth Shot LLC’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). 

F. A Summary That Can Be Published In The Federal Register, stating: The Rules 

From Which Smooth Shot, LLC Seeks Exemption:

Smooth Shot, LLC 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 Smooth Shot, LLC

Seeks: 

This exemption will permit Smooth Shot, LLC 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 Smooth Shot, LLC

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, Smooth Shot, LLC’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, Smooth Shot, LLC 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, Smooth Shot, LLC 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 DJI 

Inspire 1 UAS 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 
23

2012, while also advancing the interests of the public, by allowing Smooth Shot, LLC 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, Smooth Shot, LLC 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 

Smooth Shot, LLC 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 27, 2015.

Submitted by,

Smooth Shot, LLC

____________________________________

Alex Boling, Co-Founder

Smooth Shot, LLC

9131 Blanco Dr

Lantana, TX 76226

Tel: 469-236-2005

Appendices:

A—DJI Inspire 1 Specifications Data Sheet

B—DJI Inspire 1 Manufacturer’s User Manual

C—Monthly Maintenance Log
24

APPENDIX—A

Smooth Shot, LLC’s only utilizes safe and reliable UASs. 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).

3.2 DJI Inspire 1 

3.2.1 Aircraft 

3.2.1.1 Model – T600 

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

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

3.2.1.4 Max Angular Velocity – Pitch: 3000/s; Yaw: 1500/s 

3.2.1.5 Max Tilt Angle - 350 3.2.1.6 Max Ascent Speed – 5m/s 

3.2.1.7 Max Descent Speed – 4m/s 3.2.1.8 Max Speed – 22m/s (ATTI mode, no wind –

NOT RECOMMENDED) 

3.2.1.9 Max Flight Altitude – 4500m 3.2.1.10 Max Wind Resistance – 10m/s 

3.2.1.11 Max Flight Time – Approximately 18 minutes 

3.2.1.12 Motor Model – DJI 3510 

3.2.1.13 Propeller Model – DJI 1345 

3.2.1.14 Operating Temperature Range – 140F to 1040F (-100C to 400C) 

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

3.2.2 Gimbal 

3.2.2.1 Model – ZENMUSE X3 

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

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

3.2.2.4 Angular Vibration Range - ±0.030

3.2.2.5 Mounting – Detachable 

3.2.2.6 Controllable Range – Pitch: -900 to +300; Pan: ±3200

3.2.2.7 Mechanical Range – Pitch: -1250 to 450; Pan: ±3300

3.2.2.8 Max Controllable Speed – Pitch: 1200/s; Pan: 1800/s 

3.2.3 Camera 

3.2.3.1 Name – X3 

3.2.3.2 Model – FC350 

3.2.3.3 Total Pixels – 12.76M 

3.2.3.4 Effective Pixels – 12.4M 31 

3.2.3.5 Image Max Size – 4000x3000 

3.2.3.6 ISO Range – 100-3200 

3.2.3.7 Field of View - 940

3.2.3.8 CMOS – Sony EXMOR 1/2.3” 

3.2.3.9 HD Video Recording – UHD(4K): 4096x2160p24/25, 3840x2160p24/25/30; 

FHD: 1920x1080p24/25/30/48/50/60; HD: 1280x720p24/25/30/48/50/60 

3.2.3.10 Operating Temperature Range - 320F - 1040F (00C - 400C) 
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3.2.4 Transmitter 

3.2.4.1 Name – C1 

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

3.2.4.3 Communicating Distance (unobstructed) – 2000m 

3.2.4.4 Output Power – 9W 

3.2.4.5 Operating Temperature Range - 140F to 1040F (-100C to 400C) 

3.2.4.6 Battery – 600mAh LiPo 2S
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APPENDIX—B

DJI Inspire 1 Manufacturer’s User Manual

User manual can be found at:

http://download.dji-innovations.com/downloads/inspire_1/en/Inspire_1_User_Manual_v1.2_en.pdf

 
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APPENDIX--C