January 21, 2016

Branden Granger

Granger Aerial Services

Owner: Branden Granger

5370 W Patricia Dr.

Connersville, IN 47331

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

Aviation Regulations from: 14 CFR 21 subpart H; 14 CFR 45.23(b); 14 CFR 61.113(a) and (b); 14 CFR 

91.7(a); 14 CFR91.9(b)(2); 14 CFR 91.103; 14 CFR 91.109; 14 CFR 91.119(c); 14 CFR 91.121; 14 CFR 

91.151(a); 14 CFR 91.203 (a) and (b); 14 CFR 91.405 (a); 14 CFR 91.407 (a) (1) 14 CFR 91.409 (a)(1) and

(2); 14 CFR 91.417(a) and (b)

Dear Sir or Madam:

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the “Reform Act”) and 14 

CFR Part 11, Branden Granger, operator of an Unmanned Aircraft System (UAS), hereby applies for an 

exemption from the listed Federal Aviation Regulations (“FARs”) to allow commercial operation of its 

UAS, so long as such operations are conducted within and under the conditions outlined herein or as 

may be established by the FAA as required by Section 333.

Commercial operation of an UAS, as described herein, which are equipped with camera(s) and sensors, 

would operate in the following manner:

 Aerial photography and/or video for public and/or private use including real estate, 

architecture, land surveying, engineering and other related professional activities.

 Aerial video and/or photography for public and/or private use including television, public 

events, cinematography and newsgathering.

 Aerial inspection/photography of residential/commercial structures under contract with the 

owner or local government authority. Aerial inspection/photography of residential/commercial 

utility infrastructure including but not limited to electrical power lines, wind turbines and cell 

towers.

 Aerial video/photography or providing live video feed to assist with search and rescue 

operations in cases of an emergency or natural disaster only when the local authorities or 

government has requested it by contract or donation.

 The ability to offer training to persons individually or belonging to both private and/or public

organizations that have interests in the use and application of a UAS for the purpose of the safe

operation of a UAS to enhance the safety of the National Airspace System (NAS) as well as for

the protection of the persons and property. As described fully below, the requested exemption 

would permit the operation of a UAS under controlled conditions in the NAS that would be a) 

limited b) controlled c) predetermined and d) will provide safety enhancements to the already 

safe operations in the industry presently using conventional aircraft. Approval of this exemption 

would thereby enhance safety and fulfill the Secretary of Transportation’s (the FAA

Administrator’s) responsibilities to “....establish requirements for the safe operation of such 

aircraft systems in the national airspace system.” (continued next page)
The name and address of the applicant is:

Granger Aerial Services

Attn: Branden Granger, Owner/Chief Pilot

Email: branden.granger@icloud.com

Address: 5370 W Patricia Dr. Connersville, IN 47331

Regulations from which the exemption is requested:

14 CFR Part 21 subpart H

14 CFR 45.23 (b)

14 CFR 61.113 (a) & (b)

14 CFR 91.7 (a)

14 CFR 91.9 (b) (2)

14 CFR 91.103

14 CFR 91.109

14 CFR 91.119 (c) s

14 CFR 91.121

14 CFR 91.151 (a)

14 CFR 91.203 (a) & (b)

14 CFR 91.405 (a)

14 CFR 91.407 (a) (1)

14 CFR 91.409 (a) (2)

14 CFR 91.417 (a) & (b)

We are petitioning for exemption to enable Granger Aerial Services to operate a DJI Inspire 1 equipped 

with a three-axis gimbal and using High-Definition camera. This UAS has a built-in capability to limit the 

height it flies above the ground, to limit the radius of the distance it flies from the operator and to 

exclude it from flying in Class A, B, C, and D airspace including a no-fly zone feature near smaller 

airports. The Inspire 1 also has the fail-safe function of the Naza-M autopilot system, which means when 

the communication between the Main Controller and the transmitter is disconnected, the GPS equipped 

DJI Inspire will automatically trigger a Return to Home function and will land safely. The DJI Inspire 1 has 

a maximum gross weight of 6 pounds 7.5 ounces, a length of 17.3 inches, width of 17.7 inches, height of 

11.8 inches, and a maximum speed of approximately 42 knots. The DJI Inspire 1 UAS is equipped with 

four main rotors; driven by Lithium Polymer battery powered electric motors. Given the small size of the 

UAS and the controlled environment provided the proposed operations would adhere to the Reform 

Act’s safety requirements. The approval of this application presents no national security issues. 

Regarding the level of safety surrounding the proposed operations and the public benefit, reduction in 

environmental impacts, including but not limited to reduced emissions and noise, the grant of the 

requested exemption is in the public interest. Accordingly the applicant requests that the FAA grant the 

requested exemption with minimum delay.

AIRCRAFT AND EQUIVALENT LEVEL OF SAFETY

The operation limitations proposed for an equivalent or higher level of safety because operations will 

further enhance the safety of the persons and/or property using conventional aircraft.
These limitations and conditions to which the applicant agrees to adhere to when conducting 

commercial operations under the FAA issued exemption as set forth in the Flight Operations Manual 

(FOM) include:

 The UAS will weigh less than 55 lbs.

 The UAS will have a maximum operating speed of no more than 40mph.

 Flights will be operated within line of sight of the Pilot in Command (PIC) and/or Visual

Observer (VO).

 Maximum flight time for each operational flight will be 20 minutes. Flights will be terminated at 

25% battery power reserve or 20 minutes of flight time whichever occurs first.

 Flights will be operated at an altitude of no more than 400 feet Above Ground Level (AGL) and

not more than 200 feet above an elevated platform from which filming is planned.

 Minimum crew for each operation will consist of the UAS Pilot, the Visual Observer (VO) and

may include but not limited to a Camera Operator.

 The UAS pilot will be a designated Pilot in Command (PIC) and will take and pass all necessary

certifications currently being approved by the FAA administration for commercial use.

 A briefing will be performed regarding the planned UAS operations prior to each day’s flight

consisting of all the days’ production activities.

 All flights will occur under Visual Flight Rules Meteorological Conditions (VMC) only.

 The flights will occur no closer than a 5 mile radius of the geographic center/Airport Reference

Point (ARP) of a tower controlled or uncontrolled airport.

 The DJI Inspire 1 has built in software for all FAA regulated ‘No Fly Zones’ and is updated by DJI 

on a regular basis. This is checked prior to any flight to prevent any possible flights occurring 

within no-fly zones. 

 DJI Inspire 1 has installed software (code) that denies flights within the FAA no-fly zones. If 

operations will be within a 5 mile radius of the geographic center/Airport Reference Point (ARP) 

of a tower controlled or uncontrolled airport the respective airports will be contacted advising 

them of the estimated flight time, flight duration, elevation of flight and other pertinent 

information.

 The operator will file FAA Form 7711-1, or its equivalent, as modified in light of the requested

exemption, with the appropriate local Flight Standards District Office (FSDO) no more than 72

hours but no less than 48 hours from planned operation.

 The operator will obtain verbal/written consent of all persons involved with the planned

operation and ensure that only consenting persons will be allowed within 100 feet of the flight

operation, and the radius may be reduced to 30 feet based upon an equivalent level of safety

determination, as required under the FOM. With the advanced permission of the FSDO,

operations at closer range may be approved.

 The PIC and VO will have been trained in operation of UAS and receive up-to-date information

for the particular UAS to be operated.

 The PIC and VO will be able to communicate by voice or radio at all times.

 Written and/or verbal permission and permits will be obtained from territorial, state, county or 

city jurisdictions, including law enforcement, fire or other appropriate governmental agencies.

 If the UAS loses communications with the remote controller or loses GPS signal, the UAS will

have the capability to return to a pre-determined location within a designated location and land 

autonomously.

 The UAS will have the capability to abort a flight in case of unpredicted obstacles, weather, or 

emergencies.
14 C.F.R. Part 21, Subpart H: Airworthiness Certificates 14 C.F.R. §91.203 (a) (1)

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 and limited operating area 

associated with the aircraft to be utilized by the Applicant, an exemption from Part 21 Subpart H meets 

the requirements of an equivalent level of safety under Part 11 and Section 333 of the Reform Act. The 

Federal Aviation Act (49 U.S.C.§44701 (f)) 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 particular 

UAS. In all cases, an analysis of these criteria demonstrates that the UAS operated without an 

airworthiness certificate, in the restricted environment and under the conditions proposed will be at 

least as safe, or safer, than a conventional aircraft (fixed wing or rotorcraft) operating with an 

airworthiness certificate without the restrictions and conditions proposed.

The UAS to be operated hereunder is less than 55 lbs. (3 lbs.) fully loaded, carries neither a pilot nor 

passenger, carries no explosive materials or flammable liquid fuels, and operates exclusively within a 

secured and designated area. Unlike other civil aircraft, operations under this exemption will be tightly 

controlled and monitored by both the operator and under the requirements and in compliance with 

local public safety requirements. The FAA will have advance notice of all operations. These safety 

enhancements provide a greater degree of safety to the public and property owners than conventional 

operations conducted with airworthiness certificates issued under 14 C.F.R. Part 21, Subpart H. Lastly, 

application of these same criteria demonstrates that there is no credible threat to national security 

posed by the UAS, due to its size, speed of operation, location of operation, lack of explosive materials 

or flammable liquid fuels, and inability to carry a substantial external load.

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

The regulation requires: When marks include only the Roman capital letter "N" and the registration 

number is displayed on limited, restricted or light-sport 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," "light-sport," "experimental," or "provisional," as applicable. 

Even though the UAS will have no airworthiness certificate, an exemption will be needed as the UAS will 

have no entrance to the cabin, cockpit or pilot station on which the word “Experimental” can be placed. 

Given the size of the UAS, two-inch lettering will be impossible. The word “Experimental” will be placed 

on the fuselage in compliance with §45.29 (f).

The equivalent level of safety will be provided by having the UAS marked on its fuselage as required by

§45.29 (f) where the pilot, observer and others working with the UAS will see the identification of the 

UAS as “Experimental.”
14 C.F.R. § 61.113 (a) and (b): Private Pilot Privileges and Limitations: Pilot in

Command.

Pursuant to 14 CFR 61.113 (a) & (b), no person who holds a private pilot certificate may act as a pilot in

command of an aircraft that is carrying passengers or property for compensation or hire. An equivalent 

level of safety can be achieved by current Regulations because the applicant’s UAS do not carry any 

pilots or passengers nor property. The risks attendant to the operation of UAS is far less than the risk 

levels inherent in the commercial activities outlined in 14 CFR 61. The operation and limitations set forth 

in the FOM will equate to the safe operation of the UAS.

14 C.F.R. §91.7(a): Civil Aircraft Airworthiness.

The regulation requires that no person may operate a civil aircraft unless it is in airworthy condition. As 

there will be no airworthiness certificate issued for the aircraft, should this exemption be granted, no 

FAA regulatory standard will exist for determining airworthiness. Given the size of the aircraft for 

maintenance and use of safety check lists prior to each flight an equivalent level of safety will be 

provided.

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

Section 91.9 (b) (2) 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. The UAS, given its size and configuration 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 maintained by keeping the flight manual at the ground control point where the pilot flying 

the UAS will have immediate access to it.

14 C.F.R. § 91.103: Preflight Action.

This regulation requires each pilot in command to take certain actions before flight to insure the safety 

of flight. As FAA approved rotorcraft flight manuals will not be provided for the aircraft an exemption 

will be needed. The PIC will take all actions as stated in the manufacturer FOM in the pre-flight 

inspection section, including but not limited to reviewing weather, flight battery requirements, landing 

and takeoff distances and aircraft performance data before initiation of flight.

14 C.F.R. §91.109: Flight Instruction.

Section 91.103 provides 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. UAS and 

remotely piloted aircraft, by their design do 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 FAA has approved exemptions for flight training without fully functional dual 

controls for a number of aircraft and for flight instruction in experimental aircraft. The equivalent level 

of safety provided by the fact that neither a pilot nor passengers will be carried in the aircraft and by the 

size and speed of the aircraft.
14 C.F.R. §91.119: Minimum Safe Altitudes.

Section 91.119 establishes safe altitudes for operation of civil aircraft. Section 91.119 (d) allows 

helicopters to be operated at less than the minimums prescribed, provided the person operating the 

helicopter complies with any route or altitudes prescribed for helicopters by the FAA. As this exemption 

is for a UAS that is a helicopter and the exemption requests authority to operate at altitudes up to 400 

AGL, or not more than 200 above an elevated platform from which filming is planned, an exemption 

may be needed to allow such operations. As set forth herein, the UAS will never operate at higher than 

400 AGL with the exception that in circumstances where the UAS is used to survey or photograph a 

structure whose height exceeds 400 feet AGL, the UAS will not be operated more than 200 feet above 

the highest point on the structure. It will however be operated in a restricted area with security 

perimeter, where buildings and people will not be exposed to operations without their pre-obtained 

consent. The equivalent level of safety will be achieved given the size, weight, speed of the UAS as well 

as the location where it is operated. No flight will be taken without the permission of the property 

owner or local officials. Because of the advance notice to the property owner and participants in the 

filming activity, all affected individuals will be aware of the planned flight operations. Compared to flight 

operations with aircraft or rotorcraft weighting far more than the maximum 55lbs. proposed herein and 

the lack of flammable fuel, any risk associated with these operations is far less than those presently

presented with conventional aircraft operating at or below 500 AGL. In addition, the low-altitude 

operations of the UAS will ensure separation between these UAS operations and the operations of 

conventional aircraft that must comply with Section 91.119.

14 C.F.R. §91.121 Altimeter Settings.

This regulation requires each person operating an aircraft to maintain cruising altitude by reference to 

an altimeter that is set “...to the elevation of the departure airport or an appropriate altimeter setting 

available before departure.” As the UAS may not have a barometric altimeter, but instead a GPS altitude 

read out, an exemption may be needed. An equivalent level of safety will be achieved by the operator, 

pursuant to the safety check list and live flight data monitoring, confirming the altitude of the launch 

site shown on the GPS altitude indicator before flight.

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

(a) 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 battery powering the UAS 

provides approximately 18 minutes of powered flight. To meet the 30 minute reserve requirement in

14 CFR §91.151, UAS flights would be limited to approximately 10 minutes in length. Given the 

limitations on the UAS’s proposed flight area and the location of its proposed operations within a 

predetermined area, a longer time frame for flight in daylight or twilight VFR conditions is reasonable. 

Applicant believes that an exemption from 14 CFR §91.151(a) falls within the scope of prior exemptions. 

Operating the UAS, in a tightly controlled area where only people and property owners or official 

representatives who have signed waivers will be allowed, with less than 30 minutes of reserve fuel, does 

not engender the type of risks that Section 91.151(a) was intended to alleviate given the size and speed 

of the small UAS. Additionally, limiting UAS flights to 10 minutes would greatly reduce the utility for 

which the exemption will be granted. Applicant believes that an equivalent level of safety can be 

achieved by limiting flights to 20 minutes or 25% of battery power— whichever happens first. This 
restriction would be more than adequate to return the UAS to its planned landing zone from anywhere

in its limited operating area. 

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

The regulation provides in pertinent part: (a) except as provided in § 91.715, no person may operate a 

civil aircraft unless it has within it the following: (1) 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 UAS fully loaded weighs no more than 55 

lbs. and is operated without an onboard pilot. As such, there is no ability or place to carry certification 

and registration documents or to display them on the UAS. 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; to the extent they are applicable to the UAS.

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

These regulations require 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...,” and 

others shall inspect or maintain the aircraft in compliance with Part 43. Given that these section and

Part 43 apply only to aircraft with an airworthiness certificate, these sections will not apply to the

applicant. Maintenance will be accomplished by the operator pursuant to the flight manual and 

operating handbook. An equivalent level of safety will be achieved because the UAS is very limited in 

size and will carry a small payload and operate only in restricted areas for a limited period of time. If 

mechanical issues arise the UAS can land immediately and will be operating from no higher than 400 

feet AGL. The operator will ensure that the UAS is in working order prior to initiating flight, perform 

required maintenance, and keep a log of any maintenance performed. Moreover, the operator is the 

person most familiar with the aircraft and best suited to maintain the aircraft in an airworthy condition 

to provide the equivalent level of safety. An equivalent level of safety will be achieved because 

maintenance and inspections will be performed in accordance with the UAS Manufacturer's User 

Manual. As provided in the FOM, the operator will ensure that the UAS is in working order prior to 

initiating flight and perform required maintenance needed.

Public Interest

Manned aircraft conducting aerial photography/videography can weigh 6,000 pounds or more and 

contain one or more individuals on board. Granger Aerial Service’s UAV will weigh less than 7 pounds 

and contain no living crew (the PIC and VO being remotely located from the UAV). The limited weight 

significantly reduces the potential for harm to participating and nonparticipating individuals or property 

in the event of an incident or accident. There is no risk to an onboard crew while using a UAV.
Traditional manned aircraft contain highly flammable fuel and are at risk of fuel spillage and fire in the 

event of an incident or accident. The battery-powered Inspire 1 carries no fuel, eliminating this fire and 

environmental risk. 

Traditional aerial photography/videography operations using conventional aircraft can operate in very 

close proximity to persons and property on the ground. While the FAA mitigates these risks in a variety 

of ways, the proposed UAS operations would reduce risks even further due to the limited size, weight, 

speed, operating conditions, and safety features of the Inspire 1.

Furthermore, as Congress outlined in the FAA Modernization and Reform Act, integration of UAS into 

the National Airspace System is inherently in the public interest, as long as it can be accomplished safely.

As described above, not only will the proposed UAS operations provide an equivalent level of safety to 

current operations – they will actually provide a greatly improved level of safety to construction 

managers and the general public.

Conclusion

Granger Aerial Services seeks exemption from the FARS outlined above in order to commercially operate 

a small UAV that weighs less than seven pounds for the purposes described above.

The operation of the UAS described herein, under the strict conditions outlined above and in the 

operating documents, will provide an equivalent level of safety to support the grant of the requested 

exemptions.

Please do not hesitate to contact me if you have any questions or concerns.

Sincerely,

Branden Granger

Owner, Granger Aerial Services