1

UNITED STATES OF AMERICA 

DEPARTMENT OF TRANSPORTATION 

FEDERAL AVIATION ADMINISTRATION 

WASHINGTON, DC

Regulatory Docket No. _______________

IN THE MATTER OF THE PETITION FOR EXEMPTION OF:

ANDREW ADAM

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 THE 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 November 30, 2015 

Andrew Adam

2382 Chad Crossing

St. Charles, MO 63303

636-600-1711
2

TABLE OF CONTENTS

Page 

GLOSSARY OF 

ABBREVIATIONS............................................................................................................3 

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

INTRODUCTION AND INTERESTS OF PETITIONER.................................................4 

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

BASIS FOR 

PETITION...........................................................................................................................5 

NAME AND ADDRESS OF PETITIONER......................................................................6

THE SPECIFIC SECTIONS OF 14 C.F.R. FROM WHICH ANDREW ADAM SEEKS 

EXEMPTION......................................................................................................................7

THE EXTENT OF RELIEF ANDREW ADAM SEEKS AND THE REASON ANDREW 

ADAM SEEKS THE RELIEF.......................................................................................10

THE REASONS WHY GRANTING ANDREW ADAM’s REQUEST WOULD BE IN 

THE PUBLIC INTEREST .../..........................................................................................13

THE REASONS WHY GRANTING THE EXEMPTION WOULD NOT ADVERSELY 

AFFECT SAFETY............................................................................................................15

CONCLUSION.................................................................................................................25

APPENDIX.......................................................................................................................26
3

GLOSSARY OF ABBREVIATIONS

AGL Above Ground Level

AOI Area of Interest

ATC Air Traffic Control

ATO Air Traffic Organization

AV Aerial Vehicle

CFR Code of Federal Regulations

COA Certificate of Authorization

FAA Federal Aviation Administration

FAR Federal Aviation Regulation 

GCS Ground Control Station 

GPS Global Positioning System

LOL Loss of Link 

NAS National Airspace System

NOTAM Notice to Airman

PIC Pilot In Command

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

SO Safety Observer

SOP Standard Operating Procedures

UA Unmanned Aircraft

UAS Unmanned Aircraft System

VFR Visual Flight Rules

VLOS Visual Line of Site

VMC Visual Meteorological Conditions

VTOL Vertical Takeoff and Landing
4

SUMMARY

Andrew Adam 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 

Andrew Adam to operate an Unmanned Aircraft System (UAS) for the commercial 

purpose of conducting aerial video and photography of to be used in weddings, special 

events, sporting events, inspection purposes, real estate and news reports over certain 

areas of the United States. 

INTRODUCTION AND INTERESTS OF THE PETITIONER

My name is Andrew Adam, I am 38 years old, with a background in Mechanical 

Engineering, photography and videography. I currently freelance my photography and 

video services as well as work as a manager over a large generator repair facility. In 

addition to this I hold a private pilot's license and a professional engineering license. My 

areas of interests include photography, videography. 

The objective is to offer services that will give customers additional options when 

shooting video and photos. I will strive to provide high quality imaging for a variety of 

commercial and public uses, specifically targeting:

● Video for real estate purposes.

● Special events (weddings, concerts, private functions).

● Video and photos for business advertizing. 

● Additional photo and video needs for design projects for myself and contracted 

UAV needs for 3rd party design agencies.
5

BACKGROUND

Unmanned Aircraft Systems: DJI Inspire 1 UAS

Andrew Adam seeks an exemption to operate DJI system for compensation or 

hire within the NAS. The DJI Inspire 1 is a vertical takeoff and landing (VTOL) 

Unmanned Aircraft (UA) with a Ground Control Station (GCS) utilizing electronic tablet 

or smart phone systems. 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 1UA is equipped with four 

main rotors; driven by Lithium Polymer battery powered electric motors. 

The DJI Inspire 1 UA that will be operated by Andrew Adam 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, Andrew Adam, pursuant to the provisions of the Federal Aviation 

Regulations (14 C.F.R. § 11.61) and the FAA Modernization and Reform Act of 2012 

(FMRA), Section 333, Special Rules for Certain Unmanned Aircraft Systems, hereby 

petitions the Administrator to commercially operate the DJI Inspire 1 UAS in the 

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, Andrew Adam operation of DJI Inspire 1 

UAS 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, Andrew Adam 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. 

Andrew Adam submits that the requested relief is proper since an equivalent level 

of safety will be ensured. Andrew Adam will use experienced personnel or technicians to 

perform maintenance, alterations, or preventive maintenance on the UAS using the 

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

Maintenance Log, and DJI Inspire 1 Instruction Manual). Furthermore, Andrew Adam 

will document and maintain all maintenance records for the and DJI Inspire 1 UAS. 

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

pilot privileges and limitations: Pilot in command, is requested by Andrew Adam 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 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. 
6

Andrew Adam seeks relief from Section 91.7(a), entitled Civil aircraft 

airworthiness, because the DJI Inspire 1 UAS does not require an airworthiness 

certificate in accordance with 14 C.F.R. Part 21, Subpart H. As such, Andrew Adam 

submits that he will ensure that the DJI Inspire 1 UAS 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 the DJI Inspire 1 Instruction Manual), 

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

Andrew Adam also seeks an exemption from the requirements of Section 91.121, 

entitled Altimeter Settings, as the DJI Inspire 1 UAs will not have a typical barometric 

altimeter onboard. However, altitude information of the DJI Inspire 1 UAs 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 Andrew Adam’s 

operation of the 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. 

Additionally, Andrew Adam seeks an exemption from the requirements of 

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

submits that safety will not be affected by operation of the 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 13.5 

minutes to the first point of intended landing and, assuming normal cruising speed, to fly 

after that for at least 4.5 minutes. 

In accordance with 14 C.F.R. § 11.81, Andrew Adam 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:

Andrew Adam

2382 Chad Crossing

St. Charles, MO 63303
7

B. The Specific Sections Of 14 C.F.R. From Which Andrew Adam Seeks Exemption. 

1. Andrew Adam 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. Andrew Adam 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. Andrew Adam 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. Andrew Adam 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: 
8

(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. Andrew Adam 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. Andrew Adam 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. Andrew Adam 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. Andrew Adam 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--
9

(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. 
10

C. The Extent Of Relief Andrew Adam Seeks And The Reason Andrew Adam Seeks 

The Relief. 

1. Extent Of Relief Andrew Adam Seeks And The Reason Andrew Adam 

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, Andrew Adam submits that an equivalent level of 

safety will be maintained because no PIC will be allowed to operate the 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 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, Andrew Adam submits that all flights of the DJI Inspire 1 UASs, 

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

Andrew Adam’s business; and (2) will not carry passengers or property for compensation 

or hire. 

2. Extent Of Relief Andrew Adam Seeks And The Reason Andrew Adam 

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 Andrew Adam to determine that the 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 Andrew Adam Aerial Operations Manual, 

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

Andrew Adam seeks the requested relief because the DJI Inspire 1 UAS do not 

require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. 

Therefore, Andrew Adam will ensure that the and DJI Inspire 1 UASs are in airworthy

condition based upon its compliance with the operating documents (i.e., Monthly 

Maintenance Log, and DJI Inspire 1 Instruction Manual) prior to every flight, and further, 

determine that the aircraft are in condition for safe flight, as stated in the conditions and 

limitations below.

3. Extent Of Relief Andrew Adam Seeks And The Reason Andrew Adam 

Seeks Relief From Section 91.121. 

Relief from Section 91.121, entitled Altimeter settings, may be required to allow 
11

flight operations of the 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), Andrew Adam seeks the 

requested relief because the DJI Inspire 1 UA altimeter may be set on the ground to zero 

feet AGL, rather than the local barometric pressure or field altitude, before each flight. 

Considering the limited altitude of the proposed operations, relief from 14 CFR 

91.121 is sought to the extent necessary to comply with the applicable conditions and 

limitations stated below. As more fully set forth herein, an equivalent level of safety will 

be maintained since the DJI Inspire 1 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 Andrew Adam Seeks And The Reason Andrew Adam 

Seeks Relief From Section 91.151(b). 

Relief from Section 91.151(b) entitled Fuel requirements for flight in VFR 

conditions, is requested to the extent required to allow flights of the battery powered DJI 

Inspire 1 UAs during daylight hours in visual meteorological conditions (VMC), under 

visual flight rules (VFR), for a total duration of 13.5 minutes to the first point of intended 

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

Andrew Adam seeks the requested relief because without an exemption from Section 

91.151(b), the flight time duration of the battery powered DJI Inspire 1 UAs will severely 

constrain the practicality of any aerial video or still photo flight operations that Andrew 

Adam proposes to conduct pursuant to this Petition. 

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

UAS, operating documents, and Andrew Adam proposed operating limitations, ensure 

that Andrew Adam will safely operate the battery powered 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 13.5 minutes to the first 

point of intended landing and, assuming normal cruising speed, to fly after that for at 

least 4.5 minutes.

5. Extent Of Relief Andrew Adam Seeks And The Reason Andrew Adam 

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, Andrew Adam requests relief 

from these Sections because the DJI Inspire 1 UASs do not require airworthiness 

certificates. As set forth more fully below, DJI Inspire 1 UASs meet the conditions of 

FMRA Section 333 for operation without an airworthiness certificate. Accordingly, 

Andrew Adam will use trained technicians to perform maintenance, alterations, or 
12

preventive maintenance on the UASs using the methods, techniques, and practices 

prescribed in the UAS operating documents (i.e., the Andrew Adam Aerial Operations 

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

Andrew Adam will document and maintain all maintenance records for the DJI Inspire 1 

UAS. 
13

D. The Reasons Why Granting Andrew Adam 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 Andrew 

Adam to safely, efficiently, and economically perform aerial video and photography of 

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

Additionally, DJI Inspire 1 UASs will decrease congestion of the NAS, reduce 

pollution, and provide significant benefits to the economy. Notably, the benefits of 

Andrew Adam’s proposed operation of the 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 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 Inspire 1 UAS would reduce the 

amount of manned aircraft in the NAS, reduce noise and air pollution, as well as increase 

the safety of life and property in the air and on the ground. 

Furthermore, by reducing the number of manned aircraft operating in the NAS, 

congestion around airports caused by arriving and departing aircraft will be reduced. The 

DJI Inspire 1 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 

Inspire 1 UAS. 

Conducting aerial acquisitions with the DJI Inspire 1 UAS, instead of manned 

aircraft, will greatly benefit the public by drastically reducing the levels of air and noise 

pollution generated during traditional aerial video and still photography flight operations. 

By using battery power and electric motors, the DJI Inspire 1 UAS produce no air 

pollution, and is the most viable environmentally conscious alternative to the cabin class, 

six cylinder internal combustion engine aircraft that are typically utilized for aerial video 

and photography, while burning approximately 20-30 gallons per hour of leaded aviation 

fuel. The DJI Inspire 1 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 Inspire 1 UAS to perform aerial acquisitions, the substantial risk 

to life and property in the air and on the ground, which is usually associated with 

traditional manned aircraft flight operations, will be substantially reduced or completely 

eliminated. Aside from the lack of flight crew members located onboard the aircraft, the 

DJI Inspire 1 UAs (weighing approximately 6 pounds 7.5 ounces, at maximum gross 

weight with length of 17.3 inches, widths of 17.7 inches, and with no fuel on board), has 

less physical potential for collateral damage to life and property on the ground, and in the 

air, compared to the manned aircraft that typically conduct similar operations (weighing 
14

approximately 6,000 pounds with a wingspan of approximately 42 feet, a length of 34 

feet, and a fuel capacity of 180 gallons). 

3. Performing Aerial Video and Photography Operations With The DJI 

Inspire 1 UAS Will Benefit The Economy. 

In addition to being safe and efficient, the DJI Inspire 1 UAS are also an 

economical alternative to using manned aircraft to conduct similar aerial operations. As 

such, operation of the DJI Inspire 1 UAS will allow United States based companies, like 

Andrew Adam, to remain competitive and contribute to growth of the U.S. economy. 

Specifically, with the rising cost of aviation fuel and the Environmental Protection 

Agency (“EPA”) regulatory actions phasing out leaded aviation fuels, U.S. owned and 

operated companies must adopt new and alternative technology in order to remain 

competitive. Operating the battery powered DJI Inspire 1 UAS is one such technology

that not only allows companies greater operational flexibility compared to manned 

aircraft, but provides such flexibility without the high operational cost of a traditional 

manned aircraft. 

By operating the DJI Inspire 1 UASs, companies such as Andrew Adam, can 

remain competitive and profitable, and therefore, provide greater job stability to 

employees and contractors, which will ultimately contribute to growth of the U.S. 

economy. Improved financial performance of U.S. companies, through commercial use of 

the DJI Inspire 1 UAS, provides a stable workforce that increases consumer spending; 

improves local, state, and federal tax revenues; and allows companies to invest in 

research and development in order to remain competitive both in the United States and 

abroad. 

4. There Are No Privacy Issues. 

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

decades, Andrew Adam’s proposed operation of the DJI Inspire 1 UASs will not 

implicate any privacy issues. Specifically, the DJI Inspire 1 UAS will be operated only in 

compliance with operating documents (i.e., the Andrew Adam Aerial Operations Manual, 

Monthly Maintenance Log, 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. 
15

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 Andrew Adam Seeks Exemption. 

1. Reasons Why The 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, Andrew Adam’s operation of the DJI 

Inspire 1 UAS meet the conditions of FMRA Section 333, and will not require an 

airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. 

Section 333 provides authority for a UAS to operate without airworthiness 

certification and sets forth requirements for considering whether a UAS will create a 

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

Specifically, FMRA Section 333 states the following, in part: 

(a) In General.--Notwithstanding any other requirement of this subtitle, and not 

later than 180 days after the date of enactment of this Act, the Secretary of 

Transportation shall determine if certain unmanned aircraft systems may 

operate safely in the national airspace system before completion of the plan 

and rulemaking required by section 332 of this Act or the guidance required 

by section 334 of this Act. 

(b) Assessment of Unmanned Aircraft Systems.--In making the determination 

under subsection (a), the Secretary shall determine, at a minimum--

(1) which types of unmanned aircraft systems, if any, as a result of their 

size, weight, speed, operational capability, proximity to airports and 

populated areas, and operation within visual line of sight do not create 

a hazard to users of the national airspace system or the public or pose 

a threat to national security; and

(2) whether a certificate of waiver, certificate of authorization, or 

airworthiness certification under section 44704 of title 49, United 

States Code, is required for the operation of unmanned aircraft 

systems identified under paragraph (1). 

(c) Requirements for Safe Operation.--If the Secretary determines under this 

section that certain unmanned aircraft systems may operate safely in the 

national airspace system, the Secretary shall establish requirements for the 

safe operation of such aircraft systems in the national airspace system. 

In seeking this exemption, Andrew Adam submits that the DJI Inspire 1 UAS can 

operate safely in the NAS pursuant to FMRA Section 333, as demonstrated by: (a) the 

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

the specific operating limitations. 

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

Characteristics.
16

The DJI Inspire 1 UAS does not create a hazard to users of the NAS or the public, 

or otherwise pose a threat to national security considering its size, weight, speed, and 

operational capability. 

i. Technical Specifications Of The DJI Inspire 1 UAS. 

The technical specifications of the DJI Inspire 1 UAS are set forth by the DJI

Inspire 1 Specifications and Data Sheet, attached hereto as Appendix A.

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

Enable The UAS To Remain Within A Defined Operational Area. 

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

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

Inspire 1 UASs is provided at pages 12-16 and 45-50 of the DJI Inspire 1 User Manuals, 

attached hereto as Exhibit A.

iii. The DJI Inspire 1 UAS is Designed For Automatic Return To 

Home Point Or Hover In The Event Of Loss Of The Control Link 

Or Navigation. 

When the Control Link is lost, the DJI Inspire 1 UAs will remain stationary, in 

flight, for 3 seconds or more. If, after 3 seconds, the 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 Inspire 1 at pages 13 

through 15 of the DJI Inspire 1 User Manuals, attached hereto as Exhibit A. 

iv. The DJI Inspire 1 GCS And Its Operation.

A complete description of the operation and specifications of the DJI Inspire 1 

GCS and flight control software is provided at pages 40 through 43 of the DJI Inspire 1 

User Manual. The DJI Inspire 1 User Manual are attached hereto as Exhibits B. 

b. Flight Operations Of the DJI Inspire 1 UAS Are Limited To The Line 

Of Sight Of A Certificated Pilot in Command With A Safety Observer. 

Andrew Adam will only utilize certificated pilots who possess a current and valid 

airman medical certificate to act as a pilot in command (PIC) of the DJI Inspire 1 UAS. 

Additionally, a safety observer will assist all pilots during flight time. 

c. Flights of the DJI Inspire 1 UASs Will Be Conducted Pursuant To 

Specific Operating Limitations. 
17

In seeking this exemption, Andrew Adam proposes to commercially operate the 

DJI Inspire 1 UAS for the special purpose of conducting aerial video and photography

over certain areas of United States, pursuant to the following specific operating 

limitations:

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

following aircraft described in the operating documents, rotorcraft UASs 

weighing less than 55 pounds maximum gross weight: DJI Inspire 1 Unmanned 

Aircraft Systems. Proposed operations of any other aircraft will require a new 

petition or a petition to amend this grant. 

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

for the purpose of aerial video and photography. 

3. The UA may not be operated at a speed exceeding 43.5 knots (50 miles per

 hour). The exemption holder may use either groundspeed or calibrated airspeed 

 to determine compliance with the 43.5 knot speed restriction. In no case will 

 the UA be operated at airspeeds greater than the maximum UA operating 

 airspeed recommended by the aircraft manufacturer.

4. . The UA must be operated at an altitude of no more than 400 feet above 

ground level (AGL). Altitude must be reported in feet AGL. 

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

times. This requires the PIC to be able to use human vision unaided by any 

device other than corrective lenses, as specified on the PIC’s FAA-issued 

airman medical certificate or U.S. driver’s license. 

6. All operations must utilize a visual observer (VO). The UA must be operated 

within the visual line of sight (VLOS) of the PIC and VO at all times. The VO 

may be used to satisfy the VLOS requirement as long as the PIC always 

maintains VLOS capability. The VO 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 VO can perform the duties required of the VO. 

7. This exemption and all documents needed to operate the UAS and conduct its 

operations in accordance with the conditions and limitations stated in this grant 

of exemption, are hereinafter referred to as the operating documents. The 

operating documents must be accessible during UAS operations and made 

available to the Administrator upon request. If a discrepancy exists between the 

conditions and limitations in this exemption and the procedures outlined in the 

operating documents, the conditions and limitations herein 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 
18

operating documents. It is the 4 operator’s responsibility to track such revisions 

and present updated and revised documents to the Administrator or any law 

enforcement official upon request. The operator must also present updated and 

revised documents if it petitions for extension or amendment to this grant of 

exemption. If the operator determines that any update or revision would affect 

the basis upon which the FAA granted this exemption, then the operator must 

petition for an 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. 

8. 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 prior to conducting further 

operations under this exemption. Functional test flights may only be conducted 

by a PIC with a VO and must remain at least 500 feet from other people. The 

functional test flight must be conducted in such a manner so as to not pose an 

undue hazard to persons and property. 

9. The operator is responsible for maintaining and inspecting the UAS to ensure 

that it is in a condition for safe operation. 

10. Prior to each flight, the PIC must conduct a pre-flight inspection and 

determine the UAS is in a condition for safe flight. The pre-flight inspection 

must account for all potential discrepancies, e.g., inoperable components, 

items, or equipment. 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. 

11. The operator must follow the UAS manufacturer’s maintenance, overhaul, 

replacement, inspection, and life limit requirements for the aircraft and aircraft 

components. 

12. Each UAS operated under this exemption must comply with all manufacturer 

safety bulletins. 

13. Under this grant of exemption, a PIC must hold either an airline transport, 

commercial, private, recreational, or sport pilot certificate. The PIC must also 

hold a current FAA airman medical certificate or a valid U.S. driver’s license 

issued by a state, the District of Columbia, Puerto Rico, a territory, a 

possession, or the Federal government. The PIC must also meet the flight 

review requirements specified in 14 CFR § 61.56 in an aircraft in which the 

PIC is rated on his or her pilot certificate. 

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

the ability to safely operate the UAS in a manner consistent with how the UAS 
19

will be operated under this exemption, including evasive and emergency

maneuvers and maintaining appropriate distances from persons, vessels, 

vehicles and structures. PIC 5 qualification flight hours and currency must be 

logged in a manner consistent with 14 CFR § 61.51(b). Flights for the purposes 

of training the operator’s PICs and VOs (training, proficiency, and experiencebuilding) and determining the PIC’s ability to safely operate the UAS in a 

manner consistent with how the UAS will be operated under this exemption are 

permitted under the terms of this 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 CFR § 

91.119. 

15. UAS operations may not be conducted during night, as defined in 14 CFR § 

1.1. All operations must be conducted under visual meteorological conditions 

(VMC). Flights under special visual flight rules (SVFR) are not authorized. 

16. The UA may not operate within 5 nautical miles of an airport reference point 

(ARP) as denoted in the current FAA Airport/Facility Directory (AFD) or for 

airports not denoted with an ARP, the center of the airport symbol as denoted 

on the current FAA-published aeronautical chart, unless a letter of agreement 

with that airport’s management is obtained or otherwise permitted by a COA 

issued to the exemption holder. The letter of agreement with the airport 

management must be made available to the Administrator or any law 

enforcement official upon request. 

17. 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. 

18. If the UAS loses communications or loses its GPS signal, the UA must return 

to a pre-determined location within the private or controlled-access property. 

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

emergencies. 

20. The PIC is prohibited from beginning a flight unless (considering wind and 

forecast weather conditions) there is enough available power for the UA to 

conduct the intended operation and to operate after that for at least five minutes 

or with the reserve power recommended by the manufacturer if greater. 

21. Air Traffic Organization (ATO) Certificate of Waiver or Authorization 

(COA). All operations shall be conducted in accordance with an ATO-issued 

COA. The exemption holder may apply for a new or amended COA if it 

intends to conduct operations that cannot be conducted under the terms of the 
20

attached COA. 

22. All aircraft operated in accordance with this exemption must be identified by

serial number, registered in accordance with 14 CFR part 47, and have 

identification (N−Number) markings in accordance with 14 CFR part 45, 

Subpart C. Markings must be as large as practicable. 6 

23. Documents used by the operator to ensure the safe operation and flight of the 

UAS and any documents required under 14 CFR §§ 91.9 and 91.203 must be 

available to the PIC at the Ground Control Station of the UAS any time the 

aircraft is operating. These documents must be made available to the 

Administrator or any law enforcement official upon request. 

24. The UA must remain clear and give way to all manned aviation operations 

and activities at all times. 

25. The UAS may not be operated by the PIC from any moving device or vehicle. 

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

nonparticipating 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 in a manner ensuring the 

safety of nonparticipating persons; and b. The owner/controller of any vessels, 

vehicles or structures has granted permission for operating closer to those 

objects 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. 

The PIC, VO, operator trainees or essential persons are not considered 

nonparticipating persons under this exemption. 

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

with permission from the property owner/controller or authorized 

representative. Permission from property owner/controller or authorized 

representative will be obtained for each flight to be conducted. 

28. 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.
21

Andrew Adam submits that the equivalent level of safety established by Section 

61.113(a) and (b) will be maintained because no PIC will be allowed to operate the DJI 

Inspire 1 UAS unless that PIC has demonstrated, by meeting minimum flight-hour and 

currency requirements, that the PIC is able to safely operate the DJI Inspire 1 UAS in a 

manner consistent with the exemption, including evasive and emergency maneuvers and 

maintaining appropriate distances from people, vessels, vehicles and structures. 

Considering Andrew Adam’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 Inspire 1 UAS, Andrew Adam 

submits that the additional manned airmanship experience of a commercially certificated 

pilot would not correlate to the airmanship skills necessary for Andrew Adam’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). 

Andrew Adam will not allow any PIC to operate the DJI Inspire 1 UAS unless 

that PIC has demonstrated, by meeting minimum flight-hour requirements or the DJI 

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

the DJI Inspire 1 UAS in a manner consistent with this exemption, including 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 Andrew Adam’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 
22

90 days (for currency purposes). The FAA finds that at a minimum, the flighthour 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 experience-building flights can also be 

conducted under the grant of exemption to accomplish the required flight time. 

During training, proficiency, and experience-building flights the PIC is required 

to operate the UA with appropriate distances in accordance with 14 C.F.R 91.119. 

Exemption No. 11138 at page 15. 

Accordingly, Andrew Adam will ensure safe operations by not allowing any PIC 

to operate the DJI Inspire 1 UAS unless that PIC has demonstrated, by meeting minimum 

flight-hour and currency requirements, that the PIC is able to safely operate the DJI 

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, Andrew Adam will ensure that the DJI Inspire 1 UAS is in 

an airworthy condition based upon the UAS’s compliance with its operating documents 

and as stated in the conditions and limitations herein. 

Additionally, the FAA has previously granted relief from Section 91.7(a) specific 

to UAS, in circumstances similar, in all material respects, to those presented herein (e.g. 

Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 

11112, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161). 

4. Reasons Why An Exemption From The Requirements Of Section 91.121 

Would Not Adversely Affect Safety.

The equivalent level of safety established by Section 91.121 will be maintained 

because the altitude information of the DJI Inspire 1 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 Andrew Adam’s operation of the 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, 
23

11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161). 

5. Reasons Why An Exemption From The Requirements Of Section 91.151(b) 

Would Not Adversely Affect Safety.

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

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

Inspire 1 UASs; (2) the limitations on the proposed flight operations; and (3) the location 

of the proposed flight operations. Accordingly, Andrew Adam will ensure that it will 

safely operate the battery powered DJI Inspire 1 UAs during daylight hours in VFR 

conditions, with enough battery power to fly for a total duration of 13.5 minutes to the 

first point of intended landing and, assuming normal cruising speed, to fly after that for at 

least 4.5 minutes. 

Here, as in Exemption No. 11109, the technical specifications of the DJI Inspire 1

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 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 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, Andrew Adam 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 Andrew Adam 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 Andrew Adam Aerial 

Operations Manual, Monthly Maintenance Log, and the DJI Inspire 1 Instruction 

Manual). Furthermore, Andrew Adam will document and maintain all maintenance 

records for the DJI Inspire 1 UASs. 

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

documents, Andrew Adam will maintain the equivalent level of safety established by 
24

Sections 91.405(a), 91.409(a)(1), and 91.409(a)(2). A copy of the DJI Inspire 1 User 

Manuals are attached hereto as Exhibit A; a copy of the DJI Inspire 1 UAS Maintenance 

LOG is attached hereto as Exhibit B. 

Likewise, the exemption sought will not adversely affect safety because Andrew 

Adam will use trained technicians to perform maintenance, alterations or preventive 

maintenance on the UAS using the methods, techniques, and practices prescribed by the 

operating documents. 

Furthermore, the exemption sought would maintain an equivalent level of safety 

established by Sections 91.407, 91.417(a) and 91.417(b), because all maintenance of the 

DJI Inspire 1 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 Andrew Adam’s proposed operating limitations, the operating 

documents, and the technical aspects of the DJI Inspire 1 UASs, Andrew Adam 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, Andrew Adam requests 

that the FAA prescribe special conditions for the intended operation of the DJI Inspire 1 

UAS, which contain such safety standards that the Administrator finds necessary to 

establish a level of safety equivalent to that established by 14 C.F.R. Part 21, Subpart H, 

and 14 C.F.R §§ 61.113(a) & (b), 91.7 (a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1),

91.409(a)(1) & (a)(2), and 91.417(a) & (b). Such special conditions will permit safe 

operation of the UAs for the limited purpose of conducting aerial video and photography

over certain areas of the United States for compensation or hire. FMRA Section 333 sets 

forth the requirements for considering whether a UAS will create a hazard to users of the 

NAS or the public, or otherwise pose a threat to national security; and further, provides 

the authority for such UAS to operate without airworthiness certification in accordance 

with any requirements that must be established for the safe operation of the UAS in the 

NAS. 

Likewise, the Administrator may prescribe special conditions pursuant to 14 

C.F.R.

§ 21.16, for operation of the DJI Inspire 1 UAS, since the airworthiness regulations of 14 

C.F.R. Part 21 do not contain adequate or appropriate safety standards, due to the novel 

or unusual design features of the aircraft. Section 21.16, entitled Special Conditions, 

states the following: 
25

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 

Inspire 1 UAS, which contain such safety standards that the Administrator finds 

necessary to establish a level of safety equivalent to that established by 14 C.F.R. Part 21, 

Subpart H, and 14 C.F.R Sections 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 

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

● A Summary That Can Be Published In The Federal Register, stating: The 

Rules From Which Andrew Adam Seeks Exemption: 

Andrew Adam 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 Andrew Adam Seeks: 

This exemption will permit Andrew Adam to commercially operate an Unmanned 

Aircraft System (UAS) for the purpose of conducting aerial video and 

photography over certain areas of the United States.

● Any Additional Information, Views, Or Arguments Available To Support 

Andrew Adam’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, Andrew Adam’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, Andrew Adam will operate the DJI Inspire 1 UAS

safely in the NAS, without creating a hazard to users of the NAS, or the public, or 

otherwise pose a threat to national security. 
26

CONCLUSION

As set forth herein, Andrew Adam 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 Inspire 1 UAS commercially, without an 

airworthiness certificate, for the limited purpose of conducting aerial video and 

photography over certain areas of the United States. By granting this Petition, the FAA 

Administrator will be fulfilling the Congressional mandate of the FAA Modernization 

and Reform Act of 2012, while also advancing the interests of the public, by allowing 

Andrew Adam to safely, efficiently, and economically operate the DJI Inspire 1 UAS 

commercially within the NAS. 

WHEREFORE, in accordance with the Federal Aviation Regulations and the 

FAA Modernization and Reform Act of 2012, Section 333, Andrew Adam 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 DJI Inspire 1 UAS commercially for the purpose of conducting aerial video and 

photography over certain areas of the United States.

Dated: November 30, 2015

Respectfully submitted,

Andrew Adam

_________________________

Andrew Adam

Andrew Adam

2382 Chad Crossing

St. Charles, MO 63303

636-600-1711

Appendices:

Appendix A - DJI Inspire 1 Specifications Data Sheet

Attachments:

Exhibit A - DJI Inspire 1 Operating and Instruction Manual

Exhibit B - Maintenance Log for the DJI Inspire 1 
27

Appendices:

Appendix A – DJI Inspire 1 Specifications Data Sheet

APPENDIX – A

DJI INSPIRE 1 TECHNICAL SPECIFICATIONS

Andrew Adam 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)

DJI Inspire 1

Aircraft

● Model – T600

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

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

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

● Max Tilt Angle - 350

● Max Ascent Speed – 5m/s

● Max Descent Speed – 4m/s

● Max Speed – 22m/s (ATTI mode, no wind – NOT RECOMMENDED)

● Max Flight Altitude – 4500m

● Max Wind Resistance – 10m/s

● Max Flight Time – Approximately 18 minutes

● Motor Model – DJI 3510

● Propeller Model – DJI 1345

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

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

Gimbal

● Model – ZENMUSE X3

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

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

● Angular Vibration Range - ±0.030

● Mounting – Detachable

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

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

● Max Controllable Speed – Pitch: 1200/s; Pan: 1800/s
28

Camera

● Name – X3

● Model – FC350

● Total Pixels – 12.76M

● Effective Pixels – 12.4M

● Image Max Size – 4000x3000

● ISO Range – 100-3200

● Field of View - 940

● CMOS – Sony EXMOR 1/2.3”

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

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

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

● Operating Temperature Range - 320F - 1040F (00C - 400C)

Transmitter

● Name – C1

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

● Communicating Distance (unobstructed) – 2000m

● Output Power – 9W

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

● Battery – 600mAh LiPo 2S