Ramin Haghighi 

President 

Millennium Property Investment Group 

24910 Las Brisas Rd. Suite 112 

Murrieta, CA 92562 

Cel1951-264-6400 

Email: 4ramin@gmail.com 

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 of 2012 

Attachments: 1) DJI Inspire 1 Quick Start Guide.Vl.4 

2) DJI Inspire 1 User Manual Vl.8 

3) DJI Inspire 1 Safety Guide Lines Vl.O 

4) DJI Inspire 1 Maintenance Manual Vl.O 

References: 1) FAA Exemption No. 11138, Regulatory Docket No. FAA-2014-0481 in 

the matter of the petition of DOUGLAS TRUDEAU. 

2) FAA Exemption No. 11136, Regulatory Docket No. FAA-2014-0508 in 

the matter of the petition of ADVANCED AVIATION S()LUTITIONS LLC. 

3) FAA Exemption No. 11080, Regulatory Docket No. FAA- 2014-0355 in 

the matter of the petition of FLYING CAM INC. 

4) FAA Exemption No. 11405, Regulatory Docket No. FAA-2015-0118 in 
The matter of the petition of BRIAN CHERRY. 

Dear Sir or Madam, 

In accordance with the FAA's Guidelines for Submitting a Petition for Exemption under 

Section 333 of the FAA Modernization and Reform Act of2012, Millennium Property 

Investment Group referred to hereafter as the petitioner, request exemption from the following 

sections of Title 14, Code of Federal Regulations§§ 

61.113(a); 61.113(b); 91.119(c); 91.121; 91.15l(a); 91.405(a); 91.407(a); 91.409(a); 91.409(a) 

(2); 91.417(a) & (b); 

In order to operate small unmanned aircraft systems (UAS) commercially in airspace regulated 

by the Federal Aviation Agency (FAA) for the purposes of aerial photography, cinematography, 

Videography, mapping, crop surveying, inspections and other flight operations that could be 

Performed safely and more cost effectively with the use of small UAS at low altitude within the 

U.S. national airspace system as compared to a manned aircraft. Operations will be performed 

only at the request of and with the authorization and permission of clients or their authorized 

agents in order to facilitate commerce and raise awareness of the beneficial uses of small 

unmanned air systems. 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. The conditions 

identified and proposed by the petitioner are drawn from references 1-3. 

TheFARS 

The petitioner seeks exemption from the above mentioned F ARs for the following reasons; 

61.113(a) & 9b); The petitioner requests relief in order to facilitate the utilizationof pilots 

who hold a Private Pilots (or greater) certificate. Any pilots operating under this exemption 
would be required to comply with any conditions as set forth and in a similar fashion to the 

previously granted exemptions. 

91.119(c) As discussed in Exemption 11138 (DOUGLAS TRUDEAU), operations 

conducted closer than 500 feet to the ground may require that the UA be operated closer than 500 

feet to essential persons, or objects that would not be possible without additional relief. The 

petitioner requests modification, waiver or exemption and clarification concerning the terms 

"congested areas" and "densely populated". The petitioner requests waiver for this condition to 

allow reasonable operations in areas of subdivisions and neighborhoods if required. 

91.121 As discussed in Exemption 1138 (DOUGLAS TRUDEAU) is inapplicable since the UAS 

does not have an altimeter but instead utilizes electronic GPS with barometric sensors for altitude 

information. 

91.15l(a) As discussed in Exemption 11136 (ADVANCED AVIATION SOLUTIONS LLC) 

prior relief has been granted for manned aircraft to operate at less than the prescribed minimums, 

including Exemption Nos, 2689, 5745, and 10650. In addition, similar VAS-specific relief has 

been granted in Exemption Nos, 8811, 10808, and 10673 for day time VFR conditions. The 

VAS provides battery power reaming in percent to the PIC. The UA batteries provide 

approximately 18 minutes of powered flight. Information provided in the operating documents 

discuss procedures regarding remaining battery power management. Those documents contain a 

condition in which the PIC will initiate a landing procedure when battery remaining reaches a 

specified level. Given the limitations on proposed operations and the location of those proposed 

operations, the FAA found that a reduced minimum reserve for flight in day time VFR conditions 

was reasonable. 

91.405(a); 91.407(a)(1); 91.409(a)(1) & (2); 91.417(a) & (b) As discussed in Exemption 1138 

(DOUGLAS TRUDEAU). The petitioner proposes to inspect and ensure that the UAS is in a 

condition for safe flight in accordance with the operating documents. The FAA found that 

adherence to the petitioner's operating documents and the conditions and limitations specified, 

describing the requirements for maintenance, inspection and recordkeeping, were sufficient to 

ensure that safety would not be adversely affected. 
TheUAS 

The DJI Inspire 1 is a highly successful consumer grade small rotorcraft in the quadcopter 

configuration with an advertised weight of2935 g designed primarily to carry aloft a high 

definition camera. It has an advertised maximum speed ofless than 30 knots (22m/s) and a 

maximum climb rate of less than 1200 feet per minute (5rnls) It is powered by four electric 

motors. It utilizes an internal inertial measuring unit (IMU) with integrated barometric sensor 

augmented with global positioning system (GPS) to maintain its geospatial orientation and 

position. It is controlled primarily through an FCC certified radio control (RC) unit. Real time 

video and telemetry information is transmitted back to a ground control station allowing the 

operator and I or PIC to monitor battery levels, GPS signal strength, altitude (AGL ), distance 

from PIC, camera imagery and camera control angle. It has failsafe modes of operation for 

either loss ofRC or GPS SIGNAL. Altitude can be limited by the onboard flight controller and 

maximum altitude can be programmed by the PIC. Battery life limits flight times to 

approximately 18 minutes. The onboard flight controller will warn the pilot via telemetry and 

external lighting cues before reaching a low battery state. An automatic termination of flight and 

landing will be initiated when the battery reaches a predetermined low state (see Phantom Quick 

Start Manual V1.4). 

Risk Mitigation 

The petitioner has reviewed FAA exemptions reference's 1-3 (Conditions and Limitations) and 

believes that the procedures specified are reasonable and will be utilized in order to manage risk 

and ensure the public's safety. A preflight checklist will be employed based on manufactures 

recommendations and operating manual. A preflight check list will be used before each flight 

(based on manufactures recommendations and operating manual) to ensure the UA is airworthy 

before every flight. Airworthiness will be maintained through routine inspections before each 

flight and maintaining both flight and maintenance logs providing UA total time, along with 

maintenance issues and trends. 

The petitioner requests that in a manner similar to reference 3, he be allowed to operate within 5 

miles of an airport provided that; 
the UA may not operate in Class B, C, or D airspace without first obtaining written approval 

from the FAA. The UAmay not operate within 5 nautical miles of the geographical center of a 

towered airport as denoted on a current FAA published aeronautical chart, unless a letter of 

agreement with the airport's management is first obtained and the operations are conducted in 

compliance with any NOTAMS. The letter of agreement with the airport management will be 

available to the Administrator upon request. 

Operations within 5 miles of an airport are not anticipated to be routine, but the petitioner is 

requesting a mechanism to facilitate such activities without requesting a new and separate 

exemption( s ), should need arise. Operations within class B airspace are requested due to the lack 

of mode C transponder. 

Public interest 

Use ofthe UAS in lieu of a manned aircraft would enhance safety and reduce the environmental 

impact as compared to similar operations conducted with manned aircraft of greater proportions, 

carrying a crew and flammable fuel. Additionally, use of the UAS in order to facilitate 

commerce could lead to economic growth. Operations for this petition will enable service for 

property owners or their designees seeking an enhanced perspective for characteristics, amenities 

and benefits of their desired photographic subjects that cannot be displayed through ground level 

videography/photography. Aerial photography is a valuable marketing tool that can lead to 

increased commerce and enhance personal photography. Crop surveying applications could lead 

to decreased use of pesticides and fertilizer and conservation of water as well as increased crop 

yields and decreased costs. Aerial surveying and inspections can increase work site efficiency, 

improve volumetric estimations and reduce risk. The petitioner will provide clients with 

photographic data for these purposes on a "for hire" basis acting as an independent contractor. A 

visual observer will be utilized. Liability insurance will be obtained commensurate with the 

granting of this request for exemption. Flight data including UA flight time, Control Unit 

operation time, incident, accident and details concerning any deviations from normal operations 

will be available to FAA for use in collecting data regarding the use of the UAS as part of this 

application. This data may be submitted to FAA via traditional means (COA monthly reports), or 

other means as the Administrator may require. 

Conclusion 
----------------~ 

The petitioner is requesting this exemption for the purposes of "aerial photography, 

cinematography, videography, mapping, crop surveying, inspections and other flight operations. 

The reason for such a general and broad based request is that the petitioner wishes to utilize a 

business strategy of horizontal integration and maximize economies of scope in order to 

capitalize on opportunities as they may arise in the future, without the long turnaround time 

associated with additional exemptions. The petitioner's business model is based on the idea of 

offering ad hoc small UAS services to individuals or companies, who wish to employ these 

services as a safe, effective and legal option to enhance their business or hobby. The petitioner's 

own market research shows pent up demand for these services currently exist, in the real estate 

market and other markets are just beginning to emerge. Although videography and photography 

are included in the request, the primary objective will be aerial survey of farm crops for precision 

agriculture. The petitioner has identified university's and other agencies that could benefit from 

the operation requested in this application. 

A quick internet search will show that many are currently operating similar UAS in exactly the 

same fashion without, it is assumed FAA authorization. The petitioner has refrained from 

engaging in commercial use of the UAS. The primary purpose of seeking this exemption is to 

obtain the capability to offer those services while remaining in compliance. Only PIC's holding 

a current Airline Transport, Commercial, Private, or Sport Pilots Certificate will be utilized as 

PIC's for operations in reference to the requested exemption .. 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 CFR 61.56 in an aircraft in which the PIC is 

rated on his or her pilot certificate. 

Respectively submitted, 

President 

Millennium Property Investments Group