UNITED STATES OF AMERICA DEPARTMENT OF 

TRANSPORTATION FEDERAL AVIATION ADMINISTRATION 

WASHINGTON, DC 

Regulatory Docket No. _______________ 

IN THE MATTER OF THE PETITION FOR EXEMPTION OF:

Marshall Hunsaker

FOR AN EXEMPTION SEEKING RELIEF FROM THE 

REQUIREMENTS OF TITLE 14 OF THE CODE OF FEDERAL 

REGULATIONS

SECTIONS 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 

91.407(a)(1), 91.409(a)(1) & (a)(2), AND 91.417(a) & (b) 

CONCERNING COMMERCIAL OPERATION OF DJI Matrice 

100 AND DJI INSPIRE 1 UNMANNED AIRCRAFT SYSTEMS

PURSUANT TO SECTION 333 OF

THE FAA MODERNIZATION AND REFORM ACT OF 2012

(PUBLIC LAW 112-95) 

Submitted on June 18, 2015 

Marshall Hunsaker - 2837 South Davis Boulevard, Utah. 84010. 
SUMMARY 

 Marshall Hunsaker 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 Marshall 

Hunsaker to operate an Unmanned Aircraft System (UAS) for the 

commercial purpose of conducting aerial video and photography for real 

estate, remote radio tower locations to check for damage, and search and 

rescue. 

INTRODUCTION AND INTERESTS OF THE PETITIONER 

Marshall Hunsaker has worked in the IT Security Industry for 5 years, 3 

years working for Enterprise Security for the State of Utah as an 

information security analyst. Marshall has been flying UAV’s for over 3 

years for recreational use. Below are the following areas that would be 

used for aerial filming

 • Sourcing GIS tagged aerial images for use in Computer Assisted 

Mass Appraisal (CAMA) systems. 

 • Aerial acquisitions used for inspections of Radio Towers 

 • Increase public knowledge of UAS and promote safe UAS 

operations. 

 • Search and Rescue operations 

BACKGROUND 

Unmanned Aircraft Systems: DJI Matrice 100, DJI Inspire 1 UASs 

Marshall Hunsaker seeks an exemption to operate DJI systems for 
compensation or hire within the NAS. The DJI Matrice 100 and 

DJI Inspire 1 are vertical takeoff and landing (VTOL) Unmanned 

Aircraft (UA) with a Ground Control Station (GCS) utilizing 

electronic tablet or smart phone systems. The DJI Matrice 100 has 

a maximum gross weight of approximately 5 pounds 3 ounces, 

while having a length of 18 inches width of 18 inches, height of 8 

inches, and a maximum speed of approximately 29 knots. The DJI 

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

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

and a maximum speed of approximately 42 knots. The DJI Matrice 

100 and DJI Inspire 1UAs are equipped with four main rotors; 

driven by Lithium Polymer battery powered electric motors. 

The DJI Matrice 100 and DJI Inspire 1 UAs that will be operated 

by Marshall Hunsaker 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, Marshall Hunsaker, 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 

Matrice 100, DJI Inspire 1 UASs in the National Airspace System 

(NAS), and for an exemption from the requirements of 14 C.F.R §§ 

61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)

(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b). 

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

associated with the unmanned aircraft and its operation, Marshall 

Hunsaker’s operation of DJI Matrice 100 and 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, Marshall Hunsaker 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. 

Marshall Hunsaker submits that the requested relief is proper since an 

equivalent level of safety will be ensured. Marshall Hunsaker will use 

experienced personnel or technicians to perform maintenance, 

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

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

Monthly Maintenance Log, and DJI Matrice 100 and DJI Inspire 1 

Instruction Manual). Furthermore, Marshall Hunsaker will document 

and maintain all maintenance records for the DJI Matrice 100 and DJI 

Inspire 1 UASs. 

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

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

by Marshall Hunsaker to the extent necessary to allow a Pilot in 

Command (PIC) holding a private pilot or higher level certificate, as 

well as an airman medical certificate, and who has demonstrated, by 

meeting minimum flight- hour and currency requirements, that the PIC 

is able to safely operate the DJI Matrice 100 and DJI Inspire 1 UASs in a 

manner consistent with this exemption, including evasive and 

emergency maneuvers and maintaining appropriate distances from 

people, vessels, vehicles and structures. 

Marshall Hunsaker seeks relief from Section 91.7(a), entitled Civil 

aircraft airworthiness, because the DJI Matrice 100 and DJI Inspire 1 

UASs do not require an airworthiness certificate in accordance with 14 

C.F.R. Part 21, Subpart H. As such, Marshall Hunsaker submits that he 

will ensure that the DJI Matrice 100 and DJI Inspire 1UASs are in an 

airworthy condition, prior to every flight, by determining that the UASs 

are in compliance with the operating documents (i.e., Monthly 
Maintenance Log, and DJI Matrice 100 and DJI Inspire 1 Instruction 

Manual), and that the aircraft are in a condition for safe flight. 

Marshall Hunsaker also seeks an exemption from the requirements of 

Section 91.121, entitled Altimeter Settings, as the DJI Matrice 100 and 

DJI Inspire 1 UAs will not have a typical barometric altimeter onboard. 

However, altitude information of the DJI Matrice 100 and DJI Inspire 

1UAs 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 Marshall Hunsaker’s 

operation of the DJI Matrice 100 and DJI Inspire 1 UASs within visual 

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

equivalent to Section 91.121. 

Additionally, Marshall Hunsaker seeks an exemption from the 

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

flight in VFR conditions. Marshall Hunsaker submits that safety will 

not be affected by operation of the DJI Matrice 100 and DJI 

Inspire 1 UAs during daylight hours in visual meteorological 

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

battery power to fly for a total duration of approximately 18.5 

minutes to the first point of intended landing and, assuming 

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

In accordance with 14 C.F.R. § 11.81, Marshall Hunsaker 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: 

Marshall Hunsaker 

2837 South Davis Boulevard 
Bountiful, Utah. 84010

Tel: (801)503-5348

Email: marshallhunsaker@msn.com 

B. The Specific Sections Of 14 C.F.R. From Marshall Hunsaker 

Seeks Exemption. 

1. Marshall Hunsaker 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. Marshall Hunsaker 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. Marshall Hunsaker 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. Marshall Hunsaker Seeks Exemption From The Requirements Of 

Section 91.151(b). 

Section 91.151, entitled Fuel requirements for flight in VFR conditions, 

subsection (b), states the following: 

(b) No person may begin a flight in a rotorcraft under VFR conditions 

unless (considering wind and forecast weather conditions) there is 

enough fuel to fly to the first point of intended landing and, assuming 

normal cruising speed, to fly after that for at least 20 minutes. 

5. Marshall Hunsaker Seeks Exemption From The Requirement Of 

Section 91.405(a). 
Section 91.405, entitled Maintenance required, subsection (a), states the 

following: 

Each owner or operator of an aircraft— 

(a) Shall have that aircraft inspected as prescribed in subpart E of this 

part and shall between required inspections, except as provided in 

paragraph (c) of this section, have discrepancies repaired as prescribed 

in part 43 of this chapter[.] 

6. Marshall Hunsaker 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. Marshall Hunsaker 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. Marshall Hunsaker Seeks Exemption From The Requirements Of 

Sections 91.417(a) And 91.417(b). 

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

state the 

following: 

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

each registered owner or operator shall keep the following records for 

the periods specified in paragraph (b) of this section: 

(1) Records of the maintenance, preventive maintenance, and 

alteration and records of the 100-hour, annual, progressive, and 

other required or approved inspections, as appropriate, for each 

aircraft (including the airframe) and each engine, propeller, 

rotor, and appliance of an aircraft. The records must include-- 

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

the work performed; and 

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

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

aircraft for return to service. 

(2) Records containing the following information: 

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

and each rotor. 

(ii) The current status of life-limited parts of each airframe, engine, 

propeller, rotor, and appliance. 

(iii) The time since last overhaul of all items installed on the aircraft 

which are required to be overhauled on a specified time basis. 
(iv) The current inspection status of the aircraft, including the time since 

the last inspection required by the inspection program under which the 

aircraft and its appliances are maintained. 

(v) The current status of applicable airworthiness directives (AD) and 

safety directives including, for each, the method of compliance, the AD 

or safety directive number and revision date. If the AD or safety 

directive involves recurring action, the time and date when the next 

action is required. 

(vi) Copies of the forms prescribed by § 43.9(d) of this chapter for each 

major alteration to the airframe and currently installed engines, rotors, 

propellers, and appliances. 

(b) The owner or operator shall retain the following records for the 

periods prescribed: 

(1) The records specified in paragraph (a)(1) of this section shall be 

retained until the work is repeated or superseded by other work or for 1 

year after the work is performed. 

(2) The records specified in paragraph (a)(2) of this section shall be 

retained and transferred with the aircraft at the time the aircraft is sold. 

(3) A list of defects furnished to a registered owner or operator 

under § 43.11 of this chapter shall be retained until the defects 

are repaired and the aircraft is approved for return to service. 

C. The Extent Of Relief Marshall Hunsaker Seeks And The Reason 

Marshall Hunsaker Seeks The Relief. 

1. Extent Of Relief Marshall Hunsaker Seeks And The Reason 

Marshall Hunsaker 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, Marshall Hunsaker submits that an 

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

allowed to operate the DJI Matrice 100 UAS or DJI Inspire 1 UAS 

unless that PIC has met certain flight-hour and currency requirements, 

demonstrating that the PIC is able to safely operate either the DJI 

Matrice 100 or DJI Inspire 1 UAS in a manner consistent with the 

operations specifications as described in this exemption, including 

evasive and emergency maneuvers, as well as maintaining appropriate 

distances from people, vessels, vehicles and structures. 

Further, Marshall Hunsaker submits that all flights of the DJI 

Matrice 100 and DJI Inspire 1 UASs, conducted by the PIC 

pursuant to the grant of this Petition: (1) will be incidental to 

Marshall Hunsaker’s business; and (2) will not carry passengers 

or property for compensation or hire. 

2. Extent Of Relief Marshall Hunsaker Seeks And The Reason 

Marshall Hunsaker 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 Marshall Hunsaker to 

determine that the DJI Matrice 100 and DJI Inspire 1 UASs are in 

airworthy condition prior to every flight by ensuring that the UAS is in 

compliance with the operating documents (i.e., the Marshall Hunsaker 

Aerial Operations Manual, Monthly Maintenance Log, and DJI Matrice 

100 and DJI Inspire 1 Instruction Manual). 
Marshall Hunsaker seeks the requested relief because the DJI Matrice 

100 and DJI Inspire 1 UASs do not require an airworthiness certificate 

in accordance with 14 C.F.R. Part 21, Subpart H. Therefore, Marshall 

Hunsaker will ensure that the DJI Matrice 100 and DJI Inspire 1 UASs 

are in airworthy condition based upon its compliance with the operating 

documents (i.e., Monthly Maintenance Log, and DJI Matrice 100 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 Marshall Hunsaker Seeks And The Reason 

Marshall Hunsaker Seeks Relief From Section 91.121. 

Relief from Section 91.121, entitled Altimeter settings, may be required 

to allow flight operations of the DJI Matrice 100 and DJI Inspire 1 

UASs, 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), Marshall Hunsaker seeks the requested relief because the 

DJI Matrice 100 and DJI Inspire 1 UA’s altimeter may be set on the 

ground to zero feet AGL, rather than the local barometric pressure or 

field altitude, before each flight. 

Considering the limited altitude of the proposed operations, relief from 

14 CFR 91.121 is sought to the extent necessary to comply with the 

applicable conditions and limitations stated below. As more fully set 

forth herein, an equivalent level of safety will be maintained since the 

DJI Matrice 100 and DJI Inspire 1 UAs 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 Marshall Hunsaker Seeks And The Reason 

Marshall Hunsaker 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 Matrice 100 and DJI Inspire 1 UAs during daylight 

hours in visual meteorological conditions (VMC), under visual flight 

rules (VFR), for a total duration of 18.5 minutes to the first point of 

intended landing and, assuming normal cruising speed, to fly after that 

for at least 4.5 minutes. Marshall Hunsaker seeks the requested relief 

because without an 

exemption from Section 91.151(b), the flight time duration of the battery 

powered DJI and DJI Inspire 1 UAs will severely constrain the 

practicality of any aerial video or still photo flight operations that 

Marshall Hunsaker proposes to conduct pursuant to this Petition. 

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

Matrice 100 and DJI Inspire 1 UASs, the DJI Matrice 100 and DJI 

Inspire 1 operating documents, and Marshall Hunsaker’s proposed 

operating limitations, ensure that Marshall Hunsaker will safely operate 

the battery powered DJI Matrice 100 and DJI Inspire 1 UAs during 

daylight hours in visual meteorological conditions (VMC), under visual 

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

of 18.5 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 Marshall Hunsaker Seeks And The Reason 

Marshall Hunsaker 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, 

Marshall Hunsaker requests relief from these Sections because the DJI 

Matrice 100 and DJI Inspire 1 UASs do not require airworthiness 

certificates. As set forth more fully below, the DJI Matrice 100 and DJI 

Inspire 1 UASs meet the conditions of FMRA Section 333 for operation 

without an airworthiness certificate. Accordingly, Matrice 100 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 (i.e., the Marshall Hunsaker 

Aerial Operations Manual, Monthly Maintenance Log, and DJI Matrice 

100 and DJI Inspire 1 Instruction Manual). Furthermore, Marshall 

Hunsaker will document and maintain all maintenance records for the 

DJI Matrice 100 and DJI Inspire 1 UASs. 

D. The Reasons Why Granting Marshall Hunsaker’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 

Marshall Hunsaker to safely, efficiently, and economically perform 

aerial video and photography of construction sites, radio towers, real 

estate, and landscape over certain areas of the United States. 

Additionally, use of the DJI Matrice 100 and DJI Inspire 1 UASs will 

decrease congestion of the NAS, reduce pollution, and provide 

significant benefits to the economy. Notably, the benefits of Marshall 

Hunsaker’s proposed operation of the DJI Matrice and DJI Inspire 1 

UASs will be realized without implicating any privacy issues. 

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

The DJI Matrice 100 and DJI Inspire 1 UAs are battery powered and 

serve as a safe, efficient, and economical alternative to the manned 

aircraft traditionally utilized to obtain aerial imagery. By reducing the 

amount of manned aircraft needed to perform aerial acquisitions, an 

exemption allowing the use of a DJI Matrice 100 or 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 Matrice 100 and DJI Inspire 1 UAs do 

not require an airport to takeoff or land. 
Likewise, a reduction of manned aircraft conducting aerial video and 

photography missions would result in fewer aircraft that must be 

handled by air traffic control during the ground, takeoff, departure, 

arrival, and landing phases of flight operations. 

2. The Public Will Benefit From The Safety And Efficiency Of The 

DJI Matrice 100 and DJI Inspire 1 UASs. 

Conducting aerial acquisitions with the DJI Matrice 100 and DJI Inspire 

1 UASs, 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 Matrice 100 and DJI 

Inspire 1 UASs 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 Matrice 100 and DJI Inspire 1 

UAs, 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 Matrice 100 and DJI Inspire 1 UASs 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 Matrice 100 and DJI Inspire 1 UAs (weighing approximately 5 

pounds 3 ounces and 6 pounds 7.5 ounces respectively, at their 

maximum gross weights with lengths of 16 inches and 17.3 inches 

respectively, widths of 16 inches and 17.7 inches respectively, 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 Matrice 100 and DJI Inspire 1 UASs Will Benefit The Economy. 

In addition to being safe and efficient, the DJI Matrice 100 and DJI 

Inspire 1 UASs are also an economical alternative to using manned 

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

DJI Matrice 100 and DJI Inspire 1 UASs will allow United States based 

companies, like Marshall Hunsaker, 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 Matrice 100 

and DJI Inspire 1 UASs 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 Matrice 100 and DJI Inspire 1 UASs, companies 

such as Marshall Hunsaker, 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 Matrice 100 and DJI Inspire 1 UASs, 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, Marshall Hunsaker’s proposed operation of the 

DJI Matrice 100 and DJI Inspire 1 UASs will not implicate any privacy 

issues. Specifically, the DJI Matrice 100 and DJI Inspire 1 UASs will be 

operated only in compliance with operating documents (i.e., the 

Marshall Hunsaker Aerial Operations Manual, Monthly Maintenance 
Log, and DJI Matrice 100 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 

Marshall Hunsaker Seeks Exemption. 

1. Reasons Why The DJI Matrice 100 and DJI Inspire 1 UAs 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, Marshall 

Hunsaker’s operation of the DJI Matrice 100 and DJI Inspire 1 UASs 

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, Marshall Hunsaker submits that the DJI 

Matrice 100 and DJI Inspire 1 UASs can operate safely in the NAS 

pursuant to FMRA Section 333, as demonstrated by: (a) the 

characteristics of the DJI Matrice 100 and DJI 

Inspire 1 UASs; (b) the pilot certification requirement; and (c) 

the specific operating limitations. 

a. The Specifications Of The DJI Matrice 100 and DJI Inspire 1 

UASs Demonstrate Its Safe Characteristics. 

The DJI Matrice 100 and DJI Inspire 1 UASs do not create a hazard to 

users of the NAS or the public, or otherwise pose a threat to national 

security considering its size, weight, speed, and operational capability. 

i. Technical Specifications Of The DJI Matrice 100 and DJI Inspire 1 

UASs. 
The technical specifications of the DJI Matrice 100 and DJI Inspire 1 

UASs are set forth by the DJI Matrice 100 and DJI Inspire 1 

Specifications and Data Sheet, attached hereto as Exhibit A and B. 

ii. The DJI Matrice 100 and DJI Inspire 1 UASs Autonomous Flight 

And Navigation Modes Enable The UASs To Remain Within A 

Defined Operational Area. 

The DJI Matrice 100 and DJI Inspire 1 UASs may be operated in both 

manual and fully autonomous flight modes. A complete description of 

the flight and navigational modes of the DJI Matrice 100 and DJI Inspire 

1 UASs is provided at pages 25-35 of the DJI Matrice 100 and pages 

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

Exhibit C and D. 

iii. The DJI Matrice 100 and DJI Inspire 1 UASs Are Designed For 

Automatic Return To Home Point Or Hover In The Event Of Loss 

Of The Control Link Or Navigation. 

When the Control Link is lost, the DJI Matrice 100 and DJI Inspire 1 

UAs will remain stationary, in flight, for 3 seconds or more. If, after 3 

seconds, the DJI Matrice 100 and DJI Inspire 1 UAs do 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 Matrice 100 

UAS are set forth at pages 27 through 29 and for the DJI Inspire 1 at 

pages 13 through 15 of the DJI Matrice 100 and DJI Inspire 1 User 

Manuals, attached hereto as Exhibit C and D. 

iv. The DJI Matrice 100 and DJI Inspire 1 GCS And Its Operation. 

A complete description of the operation and specifications of the DJI 

Matrice 100 and DJI Inspire 1 GCS and flight control software is 

provided at pages 32 through 43 of the DJI Matrice 100 User Manual 

and pages 40 through 47 of the DJI Inspire 1 User Manual. DJI Matrice 
100 and DJI Inspire 1 User Manuals are attached hereto as Exhibits C 

and D. 

b. Flight Operations Of DJI Matrice 100 and DJI Inspire 1 UASs 

Are Limited To The Line Of Sight Of A Certificated Pilot in 

Command With A Safety Observer. 

Marshall Hunsaker 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 Matrice 100 and DJI Inspire 1 UASs. Additionally, a 

safety observer will assist all pilots during flight time. 

c. Flights Of DJI Matrice 100 and DJI Inspire 1 UASs Will Be 

Conducted Pursuant To Specific Operating Limitations. 

In seeking this exemption, Marshall Hunsaker proposes to commercially 

operate DJI Matrice 100 and DJI Inspire 1 UASs for the special purpose 

of conducting aerial video and photography over certain areas of United 

States, pursuant to the following specific operating limitations: 

1. Operations authorized by this grant of exemption will be limited to the 

following aircraft described in the operating documents, rotorcraft UASs 

weighing less than 55 pounds maximum gross weight: DJI Matrice 100 

and DJI Inspire 1 Unmanned Aircraft Systems. Proposed operations of 

any other aircraft will require a new petition or a petition to amend this 

grant. 

2. UAS operations under this exemption will be limited to conducting 

operations for the purpose of aerial video and photography. 

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

knots. 

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

above ground level (AGL), as indicated by the procedures specified in 

the operating documents unless a special request is made and approved 

by ATC. All altitudes reported to ATC must be in feet AGL. 
5. The UAs must be operated within visual line of sight (VLOS) of the 

PIC at all times. This requires the PIC to be able to use human vision 

unaided by any device other than corrective lenses, as specified on the 

PIC’s 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. 

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 third- class medical certificate. 

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

meets the operator’s qualification criteria and demonstrates the 

ability to safely 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. 

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

return to a pre- determined location within the planned operating 

area and land or be recovered in accordance with the operating 

documents. 

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

or emergencies in accordance with the operating documents. 

 24. The PIC is prohibited from beginning a flight unless (considering 

wind and forecast weather conditions) there is enough power to fly 

at normal cruising speed to the intended landing point and land the 

UA with 25% battery power remaining. 

 25. The operator must obtain an Air Traffic Organization (ATO) issued 

Certificate of Waiver or Authorization (COA) prior to conducting 

any operations under the grant of exemption. This COA will also 
require the operator to request a Notice to Airman (NOTAM) not 

more than 72 hours in advance, but not less than 48 hours prior to 

the operation. All operations shall be conducted in accordance with 

airspace requirements in the ATO issued COA including class of 

airspace, altitude level and potential transponder requirements. 

26. All aircraft operated in accordance with the exemption must be 

identified by serial number, registered in accordance with 14 C.F.R. part 

47, and have identification (N- Number) markings in accordance with 14 

C.F.R. part 45, Subpart C. Markings must be as large as practicable. 

 27. Before conducting operations, the radio frequency spectrum used 

for operation and control of the UA must comply with the Federal 

Communications Commission (FCC) or other appropriate 

government oversight agency requirements. 

 28. The documents required fewer than 14 C.F.R. 91.9 and 91.203 

must be available to the PIC at the Ground Control Station of the 

UAS any time the UAS is operating. These documents must be 

made available to the Administrator or any law enforcement 

official upon request. 

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

aviation operations and activities at all times. 

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

or vehicle. 

 31. Flight operations must be conducted at least 500 feet from all 

nonparticipating persons (persons other than the PIC, SO, operator 

trainees or essential persons), vessels, vehicles, and structures 
unless: 

a. Barriers or structures are present that sufficiently protect 

nonparticipating persons from the UA and/or debris in the event of 

an accident. The operator must ensure that nonparticipating 

persons remain under such protection. If a situation arises where 

nonparticipating persons leave such protection and are within 500 

feet of the UA, flight operations must cease immediately and/or; 

 b. The aircraft is operated near vessels, vehicles or structures 

where the owner/controller of such vessels, vehicles or structures 

has granted permission and the PIC has made a safety assessment 

of the risk of operating closer to those objects and determined that 

it does not present an undue hazard, and; 

c. Operations nearer to the PIC, SO, operator trainees or essential 

 persons do not present an undue hazard to those persons per § 

 91.119(a). 

32. All operations shall be conducted over private or controlled-access 

property with permission from the land owner/controller or authorized 

representative. Permission from land owner/controller or authorized 

representative will be obtained for each flight to be conducted. 

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

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

applicable COA must be reported to the FAA's UAS Integration Office 

(AFS-80) within 24 hours. Accidents must be reported to the National 

Transportation Safety Board (NTSB) per instructions contained on the 

NTSB Web site: www.ntsb.gov. 

2. Reasons Why An Exemption From The Requirements Of Section 

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

Marshall Hunsaker 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 Matrice 100 and DJI Inspire 1 UASs unless 

that PIC has demonstrated, by meeting minimum flight-hour and 
currency requirements, that the PIC is able to safely operate the DJI 

Matrice 100 or 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 Marshall Hunsaker’s proposed area of operations, and the 

operating limitations set forth-above; the parallel nature of private pilot 

aeronautical knowledge requirements to those of commercial pilot 

requirements (See Exemption No. 11062); and the airmanship skills 

necessary to safely operate the DJI Matrice 100 or DJI Inspire 1 UAS, 

Marshall Hunsaker submits that the additional manned airmanship 

experience of a commercially certificated pilot would not correlate to the 

airmanship skills necessary for Marshall Hunsaker’s specific proposed 

flight operations. 

The FAA has previously granted relief from Section 61.113(a) and (b) 

specific to UAS, in circumstances similar, in all material 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). 

Marshall Hunsaker will not allow any PIC to operate the DJI Matrice 

100 or DJI Inspire 1 UAS unless that PIC has demonstrated, by meeting 

minimum flight-hour requirements or the DJI Matrice 100 or DJI Inspire 

1 UAS training and currency requirements, that the PIC is able to safely 

operate the DJI Matrice 100 or DJI Inspire 1 UAS in a manner consistent 

with this exemption, including evasive and emergency maneuvers and 

maintaining appropriate distances from people, vessels, vehicles and 

structures. 

Specifically, the PIC must have accumulated and logged, in a manner 

consistent with 14 C.F.R. § 61.51(b), 25 hours of total time as a UAS 

rotorcraft pilot (with a minimum of 5 hours of those hours as a UAS 

pilot operating the same make and model of UAS to be used for 

operations under the exemption). In addition to the hour requirements, 
the PIC must accomplish 3 takeoffs and landings in the preceding 90 

days (for currency purposes). 

As in Exemption Nos. 11062, 11138, and 11153, prior documented flight 

experience that was obtained in compliance with applicable regulations 

will ensure an equivalent level of safety during Marshall Hunsaker’s 

proposed operations. The Administrator has held that prior documented 

flight experience that was obtained in compliance with applicable 

regulations would ensure safe operations, stating as follows: 

In Exemption No. 11062, the FAA required that prior to conducting 

operations for the purpose of motion picture filming (or similar 

operations), the PIC must have accumulated and logged, in a manner 

consistent with 14 CFR 61.51(b), 25 hours of total time as a UAS 

rotorcraft pilot including at least 10 hours logged as a UAS pilot with a 

multi-rotor UAS. Prior to operations under Exemption No. 11062, the 

PIC must also have accumulated and logged a minimum of 5 hours as a 

UAS pilot operating the same make and model of UAS to be used for 

operations under the exemption. For clarification, the FAA considers 

these minimum hour requirements to be inclusive rather than additive; 

i.e. 5 hours make and model time may be included in the 10 hours of 

multi-rotor time and the 10 hours may be included in the total 25 hours 

of UAS rotorcraft time. In addition to the hour requirements, the PIC 

must accomplish 3 takeoffs and landings in the preceding 90 days (for 

currency purposes). The FAA finds that at a minimum, the 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 

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, Marshall Hunsaker will ensure safe operations by not 
allowing any PIC to operate the DJI Matrice 100 or 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 

Matrice 100 or DJI Inspire 1 UAS in a manner consistent with the 

exemption, including evasive and emergency maneuvers and 

maintaining appropriate distances from people, vessels, vehicles and 

structures. 

3. Reasons Why An Exemption From The Requirements Of Section 

91.7(a) Would Not Adversely Affect Safety. 

The equivalent level of safety established by Section 91.7(a) will be 

maintained because prior to every flight, Marshall Hunsaker will ensure 

that the DJI Matrice 100 or 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 Matrice 100 and 

DJI Inspire 1 UAs 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 Marshall Hunsaker’s operation of 

the DJI Matrice 100 and DJI Inspire 1 UAs within visual line of sight, at 

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

Section 91.121. The altitude information will be generated by GPS 

equipment installed onboard the aircraft. Prior to each flight, a zero 
altitude initiation point is automatically established by the UASs at 

ground level. 

The FAA has previously granted relief from Section 91.121 specific to 

UAS, in circumstances similar, in all material respects, to those 

presented herein (e.g. Exemption Nos. 11062, 11063, 11064, 11065, 

11066, 11067, 11080, 11109, 11112, 11136, 11138, 11150, 11153, 11156, 

11157, 11158, 11159, 11160, 11161). 

5. Reasons Why An Exemption From The Requirements Of Section 

91.151(b) Would Not Adversely Affect Safety. 

A grant of this exemption would ensure an equivalent level of safety 

established by 14 C.F.R. Section 91.151(b) as a result of (1) the technical 

specifications of the DJI Matrice 100 and DJI Inspire 1 UASs; (2) the 

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

proposed flight operations. Accordingly, Marshall Hunsaker will ensure 

that it will safely operate the battery powered DJI Matrice 100 and DJI 

Inspire 1 UAs during daylight hours in VFR conditions, with enough 

battery power to fly for a total duration of 18.5 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 

Matrice 100 and DJI Inspire 1 UASs; the limitations on the proposed 

flight operations; and the location of the proposed operations, will 

ensure an equivalent level of safety established by 14 C.F.R. Section 

91.151(b). Furthermore, safety will be ensured as the DJI Matrice 100 

and DJI Inspire 1 UASs 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 Matrice 100 and 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, Marshall Hunsaker 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 Marshall 

Hunsaker 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 

Marshall Hunsaker Aerial Operations Manual, Monthly Maintenance 

Log, and DJI Matrice 100 and DJI Inspire 1 Instruction Manual). 

Furthermore, Marshall Hunsaker will document and maintain all 

maintenance records for the DJI Matrice 100 and DJI Inspire 1 UASs. 

Since the DJI Matrice 100 and DJI Inspire 1 UASs will be inspected as 

prescribed by the operating documents, Marshall Hunsaker 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 Matrice 100 and DJI 

Inspire 1 User Manuals are attached hereto as Exhibit C and D; a copy 

of the DJI Matrice 100 and DJI Inspire 1 UAS Maintenance LOG is 

attached hereto as Exhibit E. 

Likewise, the exemption sought will not adversely affect safety because 

Marshall Hunsaker 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 Matrice 100 and DJI Inspire 1 UASs 

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 Marshall Hunsaker’s proposed operating limitations, 

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

100 and DJI Inspire 1 UASs, Marshall Hunsaker 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, 

Marshall Hunsaker requests that the FAA prescribe special conditions 

for the intended operation of the DJI Matrice 100 and DJI Inspire 1 

UASs, 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 Matrice 100 and DJI Inspire 1 

UASs, since the airworthiness regulations of 14 C.F.R. Part 21 do 

not contain adequate or appropriate safety standards, due to 

the novel or unusual design features of the aircraft. Section 

21.16, entitled Special Conditions, states the following: 

If the FAA finds that the airworthiness regulations of this subchapter do 

not contain adequate or appropriate safety standards for an aircraft, 

aircraft engine, or propeller because of a novel or unusual design feature 

of the aircraft, aircraft engine or propeller, he prescribes special 

conditions and amendments thereto for the product. The special 

conditions are issued in accordance with Part 11 of this chapter and 

contain such safety standards for the aircraft, aircraft engine or propeller 

as the FAA finds necessary to establish a level of safety equivalent to 

that established in the regulations. 

See 14 C.F.R. § 21.16.

Therefore, in accordance with FMRA Section 333 and 14 C.F.R. § 

21.16, the FAA may prescribe special conditions for Leading Edge’s 

intended operation of the DJI Matrice 100 and DJI Inspire 1 UASs, 

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 Marshall Hunsaker Seeks 

Exemption: 

Marshall Hunsaker 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 Marshall 

Hunsaker Seeks: 

This exemption will permit Marshall Hunsaker 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 Marshall Hunsaker’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, Marshall Hunsaker’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, Marshall Hunsaker will operate the DJI 

Matrice 100 and DJI Inspire 1 UASs 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, Marshall Hunsaker seeks an exemption pursuant to 

14 C.F.R. § 11.61 and Section 333 of the FAA Modernization and 

Reform Act of 2012 (FMRA), which will permit safe operation of the 

DJI Matrice 100 and DJI Inspire 1 UASs commercially, without an 

airworthiness certificate, for the limited purpose of conducting aerial 

video and photography over certain areas of the United States. By 

granting this Petition, the FAA Administrator will be fulfilling the 

Congressional mandate of the FAA Modernization and Reform Act of 

2012, while also advancing the interests of the public, by allowing 

Marshall Hunsaker to safely, efficiently, and economically operate the 

DJI Matrice 100 and DJI Inspire 1 UASs commercially within the NAS. 

WHEREFORE, in accordance with the Federal Aviation Regulations 

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

Marshall Hunsaker respectfully requests that the Administrator grant this 

Petition for an exemption from the requirements of 14 C.F.R Sections 

61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 

91.409(a)(1) & (a)(2), and 91.417(a) & (b), and permit Leading Edge to 

operate the DJI Matrice 100 and DJI Inspire 1 UASs commercially for 

the purpose of conducting aerial video and photography over certain 

areas of the United States.

Dated: June 18, 2015 

Respectfully submitted, Marshall Hunsaker 

Marshall Hunsaker

2837 South Davis Boulevard, Bountiful, Utah. 84010 

Tel: (801) 503-5348

Email: marshallhunsaker@msn.com
DJI Matrice 100 TECHNICAL SPECIFICATIONS 

Marshall Hunsaker 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) 

1.1 DJI Matrice 100 

1.1.1 Aircraft

1.1.1.1 Supported Battery – DJI 5700mAH LiPo Battery

1.1.1.2 Weight – 5.3lbs 11.810oz (1242g) 1.1.1.3 Hover Accuracy 

(Ready to Fly) – Vertical: .8m; Horizontal: 2.5m 1.1.1.4 Max Yaw 

Angular Velocity - 2000/s 

1.1.1.5 Max Tilt Angel - 350

1.1.1.6 Max Ascent Speed – 6m/s

1.1.1.7 Max Descent Speed – 2m/s

1.1.1.8 Max Flight Speed – 15m/s (NOT RECOMMENDED) 

 . 1.1.2 Gimbal 

1.1.2.1 Working Current – Static: 750mA; Dynamic: 900mA 

1.1.2.2 Control Accuracy - ±0.030

1.1.2.3 Controllable Range – Pitch: -900 - 00

1.1.2.4 Maximum Angular Speed – Pitch: 900/s 

 . 1.1.3 Camera 

1.1.3.1 Operating Temperature Range - 320F - 1040F (00C - 

400C) 1.1.3.2 Sensor Size – 1/2.3”

1.1.3.3 Effective Pixels – 14M

1.1.3.4 Resolution – 4384x3288

4.1.3.5 HD Video Recording – 1080p30 & 720p
4.1.3.6 Recording Field of View - 1100/850

 . 1.1.4 Transmitter 

1.1.4.1 Operating Frequency – 5.728GHz – 5.85GHz

1.1.4.2 Communication Distance (unobstructed) – FCC 

Compliance: 800m 1.1.4.3 Receiver Sensitivity (1%PER) - 

-93dBm

1.1.4.4 Transmitter Power – FCC Compliance: 100mW

1.1.4.5 Working Voltage – 120mA@3.7V 

 . 1.1.5 Range Extender 

1.1.5.1 Operating Frequency – 2412-2462MHz

1.1.5.2 Communication Distance (unobstructed) – 500-700m 

1.1.5.3 Transmitter Power – 20dBm

1.1.5.4 Power Consumption – 2W 

APPENDIX – B 

DJI INSPIRE 1 TECHNICAL SPECIFICATIONS 

Marshall Hunsaker 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) 

2.2 DJI Inspire 1 

2.2.1 Aircraft

2.2.1.1 Model – T600

2.2.1.2 Weight (Battery Included) – 6lbs 7.5291oz (2935g)
2.2.1.3 Hovering Accuracy (GPS Mode) – Vertical: 0.5m; 

Horizontal: 

2.5m

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

2.2.1.5 Max Tilt Angle - 350

2.2.1.6 Max Ascent Speed – 5m/s

2.2.1.7 Max Descent Speed – 4m/s

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

RECOMMENDED)

2.2.1.9 Max Flight Altitude – 4500m

2.2.1.10 Max Wind Resistance – 10m/s

2.2.1.11 Max Flight Time – Approximately 18 minutes

2.2.1.12 Motor Model – DJI 3510

2.2.1.13 Propeller Model – DJI 1345

2.2.1.14 Operating Temperature Range – 140F to 1040F (-100C 

to 

400C)

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

2.2.2 Gimbal

2.2.2.1 Model – ZENMUSE X3

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

40 

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

2.2.2.4 Angular Vibration Range - ±0.030

2.2.2.5 Mounting – Detachable

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

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

2.2.2.8 Max Controllable Speed – Pitch: 1200/s; Pan: 1800/s 
2.2.3 Camera

2.2.3.1 Name – X3 

2.2.3.2 Model – FC350

2.2.3.3 Total Pixels – 12.76M

2.2.3.4 Effective Pixels – 12.4M

2.2.3.5 Image Max Size – 4000x3000

2.2.3.6 ISO Range – 100-3200

2.2.3.7 Field of View - 940

2.2.3.8 CMOS – Sony EXMOR 1/2.3”

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

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

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

2.2.3.10 Operating Temperature Range - 320F - 1040F (00C - 

400C) 

2.2.4 Transmitter 2.2.4.1 Name – C1 

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

2.2.4.3 Communicating Distance (unobstructed) – 2000m

2.2.4.4 Output Power – 9W

2.2.4.5 Operating Temperature Range - 140F to 1040F (-100C to 

400C) 2.2.4.6 Battery – 600mAh LiPo 2S