July 20th 2015

U.S. Department of Transportation

Docket Management System

1200 New Jersey Ave., SE

Washington, DC 20590

Re: Exemption Request Section 333 of the FAA Reform Act and Part 11 of the Federal

Aviation Regulations from 14 C.F.R. 45.23(b);14 CFR Part 21;14 CFR 61.113 (a) & (b);

91.7 (a);91.9 (b) (2);91.103(b); 91.109;91.119; 91.121; 91.151(a);91.203(a) & (b);91.405

(a); 91.407(a) (1); 91.409 (a) (2);91.417 (a) & (b).

Dear Sir or Madam:

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the “Reform

Act”) and 14 C.F.R. Part 11, DroneCru LLC (“DCLLC”) Applicant, operating the DJI

Inspire 1 Unmanned Aircraft System (“UAS” or “Inspire”), hereby respectfully seeks an

exemption from the Federal Aviation Regulations (“FARs”) listed below and discussed in

Appendix A. Attached as Appendix B,C is a summary of this request.

The requested exemption would permit commercial operation of DCLLC’s Inspire, which

weighs under 7 lbs. and performs aerial photography, videography, visual inspections,

search using onboard cameras. Applications for these UAS devices and associated

data processing functions include residential and commercial real estate, event

coverage, surveying, inspection, and artistic endeavors. Use of the Inspire for aerial

photography reduces the need to operate conventional aircraft for the same purpose

and provides very high quality imagery at a fraction of the cost of surveys using

conventional aircraft. These savings result in enhanced efficiency and productivity for

the affected activities, as well as environmental benefits.1

Operations under the exemption will be subject to strict operating requirements and

conditions to ensure at least an equivalent level of safety to currently authorized

operations using manned aircraft and under conditions as may be modified by the FAA

as required by Section 333.
As described more fully below, the requested exemption would authorize commercial

operations of aerial surveys and inspections using the Inspire, which at under 10 lbs. is

small in size. The Inspire will be operated under controlled conditions at low altitude in

airspace that is limited in scope, as described more fully herein; it will have automated

control features, as described below. The Inspire will be operated by an

____________________

1 See, e.g. Jack Nicas, Drones Find Fans Among Farmers, Filmmakers, WALL STREET JOURNAL

(March 10, 2014, 7:45 PM) (describing how an overseas surveyor used to spend 25,000 Euro ($34,345) to

survey 15 square kilometers with a team of 12 surveyors, and it would take 2 to 3 weeks to collect all the

data. With a Trimble UX5, he accomplished the same task for 5,000 Euro and got all the data he needed in

3 to 4 days. Because the surveys cost him less to perform, he passes those savings on to his customers.),

available at: http://online.wsj.com/news/articles/SB10001424052702304732804579425342990070808.

individual who has passed an FAA approved ground training exam and a training

program for the UAS. Finally, the airspace in which the UAS will operate will be

disclosed to the FAA in advance.

DCLLC respectfully submits that because this small, unmanned aerial vehicle—the

Inspire—will be used in lieu of comparatively hazardous operations now conducted with

fixed wing and rotary conventional aircraft, the FAA can have confidence that the

operations will achieve at least an equivalent level or greater level of safety. Approval of

this exemption would thereby enhance safety and fulfill the Secretary of

Transportation’s (the FAA Administrator’s) responsibilities under Section 333(c) of the

Reform Act to “establish requirements for the safe operation of such aircraft systems in

the national airspace system.”

The name and address of the applicant are: DroneCru LLC

Attn: Mike Morgan

Ph: 801­674­6229

Email: Mike@DroneCru.com

Address: 3216 South Highland Drive, SLC UT 84106 Suite 302

The regulations from which the exemption is requested are as follows:

● 14 C.F.R. Part 21

● 14 C.F.R. 45.23(b)

● 14 C.F.R. 61.113(a) & (b)

● 14 C.F.R. 61.133(a)
● 14 C.F.R. 91.7(b)

● 14 C.F.R. 91.9(b)(2

● 14 C.F.R. 91.109(a)

● 14 C.F.R. 91.119

● 14 C.F.R. 91.151(a)

● 14 C.F.R. 91.203(a) & (b)

● 14 C.F.R. 91.405(a)

● 14 C.F.R. 91.407(a)(1)

● 14 C.F.R. 91.409(a)(2)

● 14 C.F.R. 91.417(a)

Appendix A discusses each rule listed above and explains why exemptions pursuant to

the proposal set forth in this letter are appropriate, provide an equivalent level of safety,

and are in the public interest.

THE APPLICABLE LEGAL STANDARD UNDER SECTION 333

DCLLC submits that grant of this exemption application for use of the Inspire in

precision aerial surveys will advance the Congressional mandate in Section 333 of the

Reform Act to accelerate the introduction of UASs into the national airspace system

(“NAS”) if it can be accomplished safely. This law directs the Secretary of

Transportation to consider whether certain UASs may operate safely in the NAS before

completion of the rulemaking required under Section 332 of the Reform Act. In making

this determination, the Secretary is required to determine which types of UASs do not

create a hazard to users of the NAS or the public or pose a threat to national security in

light of the following:

● The UAS’s size, weight, speed, and operational capability;

● Operation of the UAS in close proximity to airports and populated areas; and

● Operation of the UAS within visual line of sight of the operator.

Reform Act § 333(a)(1). If the Secretary determines that such vehicles “may operate

safely in the national airspace system, the Secretary shall establish requirements for the

safe operation of such aircraft in the national airspace system.” Id. §333(c).2

The Federal Aviation Act expressly grants the FAA the authority to issue exemptions.

This statutory authority, by its terms, includes exempting civil aircraft, as the term is

defined under §40101 of the Act, from the requirement that all civil aircraft must have a
current airworthiness certificate and those regulations requiring commercial pilots to

operate aircraft in commercial service:

The Administrator may grant an exemption from a requirement of a regulation

prescribed under subsection (a) or (b) of this section or any of sections

44702­44716 of this title if the Administrator finds the exemption is in the public

interest.

49 U.S.C. §44701(f). ​See also ​49 USC §44711(a); 49 USC §44704; 14 CFR

§91.203(a)(1).

The grant of the requested exemption is in the public interest based on the clear

direction in Section 333 of the Reform Act; the additional authority in the Federal

Aviation Act, as amended; the strong equivalent level of safety surrounding the

proposed operations; and the significant public benefit, including enhanced safety and

cost savings associated with transitioning to UASs for aerial survey photography.

Accordingly, the applicant respectfully requests that the FAA grant the requested

exemption without delay.

Airworthiness of the DJI Inspire

A critical element of the exemption application involves evidence of the airworthiness of

the Inspire. DCLLC believes that it is in compliance with the requirements of Order

8130.34C, Airworthiness Certification of Unmanned Aircraft Systems and Optionally

Piloted Aircraft, in its use of systems

_________________

2 Applicant submits that this provision places a duty on the Administrator to not only process applications for

exemptions under Section 333, but for the Administrator, if he deems the conditions proposed herein require

modification in order to allow approval, to supply conditions for the safe operation of the UAS. DCLLC

welcomes the opportunity to consult with FAA staff in order to address any issues or concerns that this

proposal may raise that they believe may require modification.

developed by DJI.3 The Inspire has a high degree of redundancy and numerous safety

features, including:

● Precision Flight and Stable Hovering​: Integrated GPS autopilot system

provides position holding, altitude lock, and stable hovering to all field personnel

to focus on situational awareness and safely getting the job done
● Auto Return-To-Home​: Fail-safe feature will automatically activate in case of

signal loss with ground station, using GPS-Enabled autopilot to automatically

return and landing the craft at the original take-off point.

● Clearly Visible Battery and GPS Status​: Battery and GPS Status will be

available through airframe status lights clearly visible to the operator and

available through the ground station display.

● Configurable limitations​for area of operation and altitude for vertical and

horizontal speed

● No Waypoint Zones: ​The Ground Control Station features a function called "No

Waypoint Zones." This feature provides an extra element of safety around major

airports by not allowing the sUAS to operate within a predetermined radius of

these airports.

Additional safety features added by DCLLC in construction of the Inspire UAS include:

● High visibility lighting system

The criteria set forth in the Order specify the substantive showings of the device’s safety

and fitness for operation to ensure that the FAA has sufficient basis to evaluate the

aircraft’s safety.

Mandatory Operating Conditions

Grant of the exemption to DCLLC will be subject to the following mandatory conditions,

which are based upon operating conditions set forth for operation of UAS by public

entities pursuant to Certificates of Authorization, with additional restrictions:

● All operations to occur in Class G airspace.

● Operations to avoid congested or populated areas, which are depicted in yellow

on VFR charts.

● Operations to be conducted over private or controlled­access property.

● Permission from land owner/controller required before commencing any flight.

● Operations to occur during Visual Flight Rules Meteorological Conditions (VMC).

● Aircraft to remain within Visual Line of Sight (VLOS).

○ VLOS guaranteed with a cylinder of operation around operator of 1∕2

nautical miles (NM).

○ Cylinder walls may be expanded by observer with ability to control aircraft.

● Operations to occur during daylight hours.

● Above Ground Level (AGL) altitude to be restricted to 400 feet.
● All operations conducted in vicinity of airport to remain more than 2.5 NM from

centerline azimuth of runway centerline measured from runway thresholds.

● Operator will file a NOTAM for each flight, as required.

● All required permissions and permits will be obtained from territorial, state,

county or city jurisdictions, including local law enforcement, fire, or other

appropriate governmental agencies.

Operator Requirements

DCLLC respectfully proposes that operator requirements should take into account the

characteristics of the particular UAS. Certain UASs, such as the DCLLC Inspire, are

characterized by a high degree of pre­

____________

3 DCLLC is submitting the following documents in support of this exemption application for the Inspire: 1)

Inspire Preflight Checklist (Exhibit 1); 2) Inspire Operations and Maintenance Manual (Exhibit 2); and 3)

Inspire safety Guidelines (Exhibit 3).

programmed control and various built­in technical capabilities that limit the potential for

operation outside of the operating conditions set forth above.

The Inspire has a semi­autonomous navigation and control system comprised of a

Ground Control Station (GCS) and auto­pilot system. All flights are pre­programmed

with GPS guidance and do not require human intervention. Flight mission area and

routing cannot be changed after launch. Flights are not directed by positive manual

control, nor are evasive maneuvers. In the case of unplanned events, the operator

inputs pre­programmed evasive maneuvers from the control unit and the control unit

executes that maneuver. Pre­programmed operator interventions include diversion to

the right; initiation of holding at present position; suspension of mission; fly back to

launch point; fly to point and hold; abort mission and land; and emergency power cut off

and land (Flight Termination System).7 Additional automated safety functions and

safety enhancing features of the Inspire include the following:

● Auto­pilot detection of lost GPS or of insufficient satellites initiates an immediate

vertical landing, unless overridden by pilot in command.

● Low power on the aircraft triggers escalating alarms at GCS at 35% and 10%

levels.

● If the auto­pilot detects a lost­link to the GCS for longer than 30 seconds,

return­to­home sequence initiates.
● The Inspire is inherently unstable, so auto­pilot failure will result in a rapid exit

from flight

● Aircraft has an on­board failsafe that limits vertical speed to approximately 6 m/s

(configurable).

● The aircraft, weighing less than 7 lbs., fully loaded, is constructed of composite

material intended to absorb impact energy.

● The motors are driven by pulse width modulated signals, not analog signals.

Given these safety features, DCLLC proposes that operators of the Inspire should not

be required to hold a commercial or private pilot certification. Instead, operators should

be required to:

● have successfully completed, at a minimum, FAA private pilot ground instruction

● and passed the FAA Private Pilot written examination or FAA­recognized

equivalents;

● have successfully demonstrated capability to operate UAS in accordance with

manufacturer standards.

DCLLC notes that the FAA has found that safety factors permitted operation of UASs by

operators with these qualifications in the case of operations pursuant to public COAs

when the mandatory operating conditions specified above were present. See Federal

Aviation Administration, Notice N­8900.227, Unmanned Aircraft Systems (UAS)

Operational Approval, at 20­21 (July 30, 2013). The FAA has the statutory authority to

grant exemptions to the requirements for and privileges associated with the grant of

airmen’s certificates. 49 USC §44701 (f).

In summary, applicant seeks an exemption from the FARs set forth above and in

Appendix A to allow commercial operations of a small unmanned vehicle conducting

precision aerial surveys.

Approval of the exemption allowing commercial operations of the Inspire for precision

survey work will enhance safety by reducing risk. Conventional aerial survey operations,

using jet or piston­ powered aircraft present risks associated with vehicles that weigh in

the neighborhood of 5,000 to 7,000 lbs., or more, carry large quantities of fuel,

passengers, and, in some cases, cargo. Such aircraft must fly to and from the survey

location. In contrast, a Inspire weighing less than 7 lbs. and powered by batteries

eliminates a portion of that risk given the reduced mass and lack of combustible fuel

carried on board. The Inspire is carried to the survey location, not flown there. The
Inspire will carry no passengers or crew and, therefore, will not expose any individuals

to the risks associated with manned aircraft flights.

Additionally, no national security issue is raised by the grant of the requested

exemptions. Given the size, load carrying capacity, speed at which it operates, and the

fact that it carries no explosives or other dangerous materials, the Inspire poses no

threat to national security.

The operation of the Inspire, weighing less than 7 lbs., for precision surveys in

accordance with the strict conditions outlined above, will provide an equivalent level of

safety supporting the grant of the exemptions requested herein, including exempting

DCLLC from the requirements of Part 21.

The Inspire’s satisfaction of the criteria set forth in Section 333 of the Reform Act—size,

weight, speed, operating capabilities, lack of proximity to airports and populated areas,

operation within visual line of sight, and national security—and its showing of an

equivalent level of safety as it may relate to the requirement for a pilot’s license, provide

more than adequate justification for the grant of the requested exemptions allowing

commercial operation of the Inspire in the commercial precision aerial survey business.

Very Respectfully,

Mike Morgan

Mike Morgan

DroneCru LLC
APPENDIX A

EXEMPTION REQUEST AND EQUIVALENT LEVEL OF SAFETY

SHOWINGS UNDER APPLICABLE RULES SUBJECT TO EXEMPTION

DCLLC requests an exemption from the following regulations as well as any additional

regulations that may technically apply to the operation of the Inspire:

14 C.F.R. § 45.23(b): Marking of the Aircraft

The regulation provides:

When marks include only the Roman capital letter “N” and the registration

number is displayed on limited, restricted or light­sport category aircraft or

experimental or provisionally certificated aircraft, the operator must also display

on that aircraft near each entrance to the cabin, cockpit, or pilot station, in letters

not less than 2 inches nor more than 6 inches high, the words “limited,”

“restricted,” “light­sport,” “experimental,” or “provisional,” as applicable.

The Inspire has no entrance to the cabin, cockpit, or pilot station on which the word

“Experimental” can be placed. Given the size of the UAV, two­inch lettering will be

impossible. The word “Experimental” will be placed on the forward fuselage in

compliance with § 45.29(f).

The equivalent level of safety will be achieved by having the Inspire marked as required

by § 45.29(f) where the pilot, observer, and others working with the UAV will see the

identification of the UAS as “Experimental.” The FAA has issued the following

exemptions to this regulation, Exemption Nos. 10700, 8738, 10167 and 10167A.

14 C.F.R. Part 21, Subpart H: Airworthiness Certificates 14 CFR §

91.203(a)(1)

Section 91.203(a)(1) requires all civil aircraft to have a certificate of airworthiness. Part

21, Subpart H, entitled Airworthiness Certificates, establishes the procedural

requirements for the issuance of airworthiness certificates as required by FAR §

91.203(a)(1). Given the size of the aircraft (under 7lbs.) and the limited operating area

associated with its utilization, it is unnecessary to go through the certificate of

airworthiness process under Part 21 Subpart H to achieve or exceed current safety
levels. Such an exemption meets the requirements of an equivalent level of safety

under Part 11 and Section 333 of the Reform Act. The Federal Aviation Act and Section

333 of the Reform Act both authorize the FAA to exempt aircraft from the requirement

for an airworthiness certificate, upon consideration of the size, weight, speed,

operational capability, and proximity to airports and populated areas of the UAS

involved.

In this case, an analysis of these criteria demonstrates that the Inspire operated without

an airworthiness certificate, under the conditions proposed herein, will be at least as

safe, or safer, than a conventional aircraft (fixed wing or rotorcraft) with an airworthiness

certificate. The Inspire weighs less than 7 lbs.

fully loaded. It will not carry a pilot or passenger, will not carry flammable fuel, and will

operate exclusively within an area pre­disclosed and in compliance with conditions set

forth herein. Operations under this exemption will be tightly controlled and monitored by

both the operator, pursuant to the conditions set forth above, and by local public safety

requirements. The FAA will have advance notice of all operations through the filing of

NOTAMs. Receipt of the prior permission of the land owner, the size of the aircraft, the

lack of flammable fuel, and the fact that the aircraft is carried to the location and not

flown there all establish the equivalent level of safety. The Inspire construction with

absorbent material provides at least an equivalent level of safety to that of such

operations being conducted with conventional aircraft that would be

orders­of­magnitude larger and would be carrying passengers, cargo, and flammable

fuel.

14 C.F.R. § 61.113(a) & (b); 61.133(a): Private Pilot Privileges and

Limitations; Pilot in Command; Commercial Pilot Privileges and

Limitations.

Section 61.113(a) & (b) limit private pilots to non­commercial operations. Unlike a

conventional aircraft that carries a pilot, passengers, and cargo, the Inspire in this case

is remotely controlled with no passengers or property of others on board. Section

61.133(a) requires an individual with a commercial pilot’s license to be pilot in command

of an aircraft for compensation or hire. DCLLC respectfully proposes that operator

requirements should take into account the characteristics of the particular UAS.

DCLLC’s Inspire has a high degree of pre­programmed control and various built­in

technical capabilities that strictly limit the potential for operation outside of the operating

conditions set forth in the exemption application.
The Inspire has a semi­autonomous navigation and control system comprised of a

Ground Control Station (GCS) and auto­pilot system. All flights are pre­programmed

with precision GPS guidance and do not require human intervention. Flight mission area

and routing cannot be changed after launch. Flights are not directed by positive manual

control, nor are evasive maneuvers. In the case of unplanned events, the operator

inputs pre­programmed evasive maneuvers from the control unit, and the control unit

executes that maneuver. Pre­programmed operator interventions include diversion to

the right; initiation of holding at present position; suspension of mission; fly back to

launch point; fly to point and hold; abort mission and land; and emergency power cut off

and land (Flight Termination System).

Additional automated safety functions and safety enhancing features of the Inspire

include the following:

● Auto­pilot detection of lost GPS or of insufficient satellites initiates an immediate

spiral landing.

● Low power on the aircraft triggers escalating alarms at GCS at 35% and 10%

levels.

● If the auto­pilot detects a lost­link to the GCS for longer than 30 seconds, landing

procedure begins.

● The Inspire is inherently unstable, so auto­pilot fail will result in very rapid exit

from flight.

● Aircraft has an on­board failsafe that limits speed in the event of dive to

approximately 14 m/s.

● The aircraft, weighing less than 7 lbs., fully loaded, is constructed of composite

material which is intended to absorb impact energy.

● The motors are driven by pulse width modulated signals, not analog signals.

Given these safety features, DCLLC proposes that operators of the Inspire should not

be required to hold a commercial or private pilot certification. Instead, operators should

be required to:

● have successfully completed, at a minimum, FAA private pilot ground instruction

and passed the FAA Private Pilot written examination or FAA­recognized

equivalents;

● have completed the manufacturer’s training program for operation of the UAS.

The manufacturer’s training program will have been satisfactorily reviewed

through the SAC process.

DCLLC notes that the FAA has found that safety factors permitted operation of UASs by

operators with these qualifications in the case of operations pursuant to public COAs
where the mandatory operating conditions specified above are present. See Federal

Aviation Administration, Notice N­8900.227, Unmanned Aircraft Systems (UAS)

Operational Approval, at 20­21 (July 30, 2013). The FAA has the statutory authority,

granted at 49 U.S.C.§44701(f) to waive the pilot requirements for commercial

operations.

Given these conditions and restrictions, an equivalent level of safety will be provided by

allowing operation of the Inspire without a private pilot’s certificate or a commercial

pilot’s certificate, under the conditions set forth herein.

The risks associated with the operation of the Inspire (given its size, speed, operational

capabilities, and lack of combustible fuel) are so diminished from the level of risk

associated with private pilot operations or commercial operations contemplated by Part

61 with conventional aircraft (fixed wing or rotorcraft), that allowing operations of the

UAS as set forth above meets or exceeds the present level of safety provided under 14

C.F.R. § 61.113(a) & (b) and does not rise to the level of requiring a commercial pilot to

operate the aircraft under § 61.133(a).

14 C.F.R. § 91.7(a): Civil aircraft airworthiness.

This regulation requires that no person may operate a civil aircraft unless it is in

airworthy condition. Should the exemption be granted allowing commercial operation of

the Inspire without an airworthiness certificate, no standard will exist for airworthiness of

the Inspire. Given the size of the aircraft and the requirements that have presumably

already been met in the SAC approval process for the Inspire (for instance, the Inspire’s

Maintenance & Inspection Manual and Safety Checklist), an equivalent level of safety

will be achieved by insuring compliance with the DCLLC manuals prior to each flight.

14 C.F.R. § 91.9(b)(2): Civil Aircraft Flight Manual in the Aircraft.

The regulation provides:

No person may operate a U.S.­registered civil aircraft ...

(2)...For which an Airplane or Rotorcraft Flight Manual is not required by §21.5 of

this chapter, unless there is available in the aircraft a current approved airplane

or Rotorcraft Flight Manual, approved manual material, markings, and placards,

or any combination thereof.
Given the size and configuration of the Inspire, it has no ability or place to carry such a

flight manual on the aircraft, not only because there is no pilot on board, but because

there is no room or capacity to carry such an item on the aircraft.

The equivalent level of safety will be achieved by keeping the flight manual (see, e.g.,

User Guide, Exhibit 2) at the ground control point where the pilot flying the UAS will

have immediate access to it. The FAA has issued the following exemptions to this

regulation: Exemption Nos. 8607, 8737, 8738, 9299, 9299A, 9565, 9565B, 10167,

10167A, 10602, 32827, and 10700.

14 C.F.R. § 91.109(a) & 91.319(a)(1): Flight Instruction

These regulations provide that no person may operate a civil aircraft (except a manned

free balloon) that is being used for flight instruction unless that aircraft has fully

functioning dual controls.

The Inspire is a remotely piloted aircraft and by design, does not have fully functional

dual controls. Flight control is accomplished through the use of a control box that

communicates with the aircraft via radio communications. The flight plan is

pre­programmed into the auto pilot before flight and only in unusual circumstances will

the pilot input control functions to alter the pre­programmed flight. If instruction is

accomplished through a training program, as set forth in Exhibit 2, an equivalent level of

safety will be assured. The FAA has approved exemptions for flight training without fully

functional dual controls for a number of aircraft and for flight instruction in experimental

aircraft. See Exemption Nos. 5778K & 9862A. The equivalent level of safety will be

achieved by the manufacturer providing the training as outlined, for example, in Exhibit

2 and through the use of experienced and qualified pilots familiar with the Inspire.

14 CFR § 91.119: Minimum Safe Altitudes

Section 91.119 establishes safe altitudes for operation of civil aircraft. Specifically,

91.119(c) limits aircraft flying over areas other than congested areas to an altitude of

500 feet above the surface, except over open water or sparsely populated areas. In

those cases, the aircraft may not be operated closer than 500 feet to any person,

vessel, vehicle, or structure.

As set forth herein, the Inspire will never operate at higher than 400 feet AGL. It will,

however, be operated to avoid congested or populated areas that are depicted in yellow

on VFR sectional charts.
Because aerial survey work must be accomplished at relatively low altitudes and at

altitudes less than 500 feet AGL, an exemption from Section 91.119(c) is needed.

The equivalent level of safety will be achieved given the size, weight, speed, and

material with which the Inspire is built. Also, no flight will be taken without the

permission of the land owner or those who control the land. Because of the advance

notice to the landowner, all affected individuals will be aware of the survey flights.

Compared to aerial survey operations conducted with aircraft or rotorcraft weighing far

more than 7 lbs. and carrying flammable fuel, any risk associated with these operations

will be far less than those currently allowed with conventional aircraft operating at or

below 500 feet AGL. Indeed, the low­altitude operations of the UAS will maintain

separation between these small­ UAS operations and the operations of conventional

aircraft that must comply with Section 91.119.

14 C.F.R. § 91.151(a): Fuel Requirements for Flight in VFR Conditions

This regulation prohibits an individual from beginning “a flight in an airplane 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 –

(1) During the day, to fly after that for at least 30 minutes; or (2) At night, to fly after that

for at least 45 minutes.”

The Inspire batteries provide approximately 50 minutes of powered flight. Without an

exemption from § 14 CFR 91.151, the UAS’s flights would be limited to approximately

20 minutes in length. Given the limitations on its proposed operations and the location

of those proposed operations, a longer time frame for flight in daylight VFR conditions is

reasonable.

DCLLC believes that an exemption from 14 CFR § 91.151(a) is safe and within the

scope of a prior exemption. See Exemption 10673 (allowing Lockheed Martin

Corporation to operate without compliance with 91.151(a)). Operating the small UAS,

without 30 minutes of reserve fuel does not engender the type of risks that Section

91.151(a) was meant to prevent given the size and speed at which the UAS operates.

The fact that it carries no pilot, passenger, or cargo also enhances its safety.

Additionally, limiting Inspire flights to 20 minutes would greatly reduce their utility. In the

unlikely event that the Inspire should run out of fuel, it would simply land. Given its

weight and construction material, the risks are less than contemplated by the current

regulation.
DCLLC believes that an equivalent level of safety can be achieved by maintaining 10

minutes of reserve fuel, which, allowing 40 minutes of flight time, would be more than

adequate to return the UAS to its planned landing zone from anywhere in its operating

area.

14 C.F.R. § 91.203 (a) & (b): Carrying Civil Aircraft Certification and

Registration

This regulation provides as follows:

(a)...no person may operate a civil aircraft unless it has...an appropriate and

current airworthiness certificate.

(b) No person may operate a civil aircraft unless the airworthiness certificate

required by paragraph (a) of this section or a special flight authorization issued

under §91.715 is displayed at the cabin or cockpit entrance so that it is legible to

passengers or crew.

The Inspire fully loaded weighs no more than 7 lbs. As such, there is no ability or place

to carry certification and registration documents or to display them on the UAS. In

addition, there is no pilot on board the aircraft.

An equivalent level of safety will be achieved by keeping these documents at the ground

control point where the pilot flying the UAS will have immediate access to them. The

FAA has issued numerous exemptions to this regulation. A representative sample of

other exceptions includes Exemption Nos. 9565, 9665, 9789, 9789A, 9797, 9797A,

9816A, and 10700.

14 C.F.R. § 91.405(a); 407(a)(1); 409(a)(2); 417(a): Maintenance Inspections

Section 91.405(a) requires that an aircraft operator or owner “shall have that aircraft

inspected as prescribed in subpart E of this part and shall between required inspections,

except as provided in paragraph (c) of this section, have discrepancies repaired as

prescribed in part 43 of this chapter...” Section 91.407 similarly makes reference to

requirements in Part 43; Section 91.409(a)(2) requires an annual inspection for the

issuance of an air worthiness certificate. Section 91.417(a) requires the owner or

operator to keep records showing certain maintenance work that has been

accomplished by certificated mechanics, under Part 43, or licensed pilots and records of

approval of the aircraft for return to service.
Maintenance of the Inspire will be accomplished by the owner/operator pursuant to the

manuals, such as Exhibit 3, provided by DCLLC. An equivalent level of safety will be

achieved because the UAS is small in size, will operate only in restricted predetermined

areas, and is not a complex mechanical device. As provided in the attached User

Manual and the Safety Checklist, the operator of Inspire will ensure that the UAS is in

working order prior to initiating flight, perform required maintenance, and keep a log of

any maintenance that is performed. Moreover, the operator is the person most familiar

with the aircraft and is best suited to maintain the aircraft in an airworthy condition and

to ensure an equivalent level of safety.
APPENDIX B

SUMMARY OF DCLLC SECTION 333 EXEMPTION REQUEST

DCLLC hereby provides pursuant to Part 11 a summary of its exemption application to

allow commercial operation of the Inspire unmanned aircraft include residential and

commercial real estate, event coverage, surveying, inspection, and artistic endeavors.

An exemption is requested from the following regulations:

14 C.F.R. Part 21

14 C.F.R. 45.23(b)

14 C.F.R. 61.113(a) & (b)

14 C.F.R. 61.133(a)

14 C.F.R. 91.7(b)

14 C.F.R. 91.9(b)(2)

14 C.F.R. 91.109(a)

14 C.F.R. 91.119

14 C.F.R. 91.151(a)

14 C.F.R. 91.203(a) & (b)

14 C.F.R. 91.405(a)

14 C.F.R. 91.407(a)(1)

14 C.F.R. 91.409(a)(2)

14 C.F.R. 91.417(a)
APPENDIX – C

DJI INSPIRE 1 PROFESSIONAL TECHNICAL SPECIFICATIONS

DCLLC 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 real­time altitude

and location information to the PIC via the linked monitor (smart phone/tablet devices)

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 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 – 100­3200

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 – 5.728­5.850GHz; 2.400­2.483GHz 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