December 5, 15 2015

Attn:

U. S. Department of Transportation Docket

Operations West Building Ground Floor, Room

w12­140

1200 New Jersey Ave, SE Washington, DC 20590

RE:VENT2WIRE MARKETING dba. VENT2WIRE

REQUEST AN EXEMPTION FROM THE REQUIREMENTS OF TITLE 14 OF THE

CODE OF FEDERAL REGULATIONS

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

91.409(a)(1) & (a)(2), AND 91.417(a) & (b) CONCERNING COMMERCIAL

OPERATION OF DJI Inspire 1 UNMANNEDAIRCRAFT SYSTEMS PURSUANT TO

SECTION 333 OF

THE FAA MODERNIZATIONAND REFORMACT OF 2012 (PUBLIC LAW 112­95)

Justin Wayoro

President

VENT2WIRE MARKETING dba. VENT2WIRE

P.O Box 50335

Oxnard, Ca, 93033

805 263 7870

Info@vent2wire.com
TABLE​OF​CONTENTS

Page

GLOSSARY OF ABREVIATIONS.........................................................................2

SUMMARY.................................................................................................... 3

INTRODUCTION AND INTERESTS OF PETITIONER............................................3

BACKGROUND..............................................................................................3

BASIS FOR PETITION.....................................................................................4

NAME AND ADDRESS OF PETITIONER..............................................................5

THE SPECIFIC SECTIONS OF 14 C.F.R. FROM WHICH VENT2WIRE SEEKS

EXEMPTION ...........................................................................................6

THE EXTENT OF RELIEF VENT2WIRE SEEKS AND THE REASON VENT2WIRE

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

THE REASONS WHY GRANTING VENT2WIRE’S REQUEST WOULD BE IN THE

PUBLIC INTEREST ....................................................................12

THE REASONS WHY GRANTING THE EXEMPTION TO VENT2WIRE WOULD

NOT ADVERSELY AFFECT SAFETY ....................................14

SUMMARY THAT CAN BE PUBLISHED IN THE FEDERAL REGISTER ...........25

ANY ADDITIONAL INFORMATION, VIEWS, OR ARGUMENTS AVAILABLE TO

SUPPORT QA VENT2WIRE’S REQUEST .......................................25

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

APPENDICES........................................................................................ 26

1
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

2
SUMMARY

Vent2wire Marketing, dba. VENT2WIRE hereafter referred to as VENT2WIRE 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

(DJI Inspire 1) pursuant to Section 333 of the FAA Modernization and Reform Act of 2012

(FMRA). This exemption will permit VENT2WIRE to operate an Unmanned Aircraft System (UAS)

for the commercial purpose of conducting aerial video and photography of construction sites,

residential and commercial real estate, civil landscapes and events over certain areas of the

United States.

INTRODUCTION AND INTERESTS OF THE PETITIONER

VENT2WIRE has for over ten years provided their clients (which include private sector businesses

and non­profits, along with local state and federal agencies) with expertise and knowledge in

video and multimedia marketing, advertising, public relations and training using advanced

technologies and solutions. VENT2WIRE has worked on thousands of productions over the past

15 years in all types of locations with a perfect client and employee safety record. In the past we

have supplied our clients aerial video and photography using commercial aircraft. The objective of

VENT2WIRE and our Unmanned Aircraft System (DJI Inspire 1) aerial operations is to provide a

more affordable, high­quality production system for a variety of governmental, commercial, public,

and residential uses, specifically targeting

• Construction sites before and after

• Appraisals

• Real­estate marketing

• Economic development

• Civic landmarks

• Special event coverage

• Private and governmental training

• Motion Picture Production

We has safely flown small RC electric quadcopters recreationally for approximately 3 years

without any incident.

BACKGROUND

Unmanned Aircraft Systems: DJI Inspire 1, UAS

VENT2WIRE seeks an exemption to operate DJI Inspire 1 system for compensation or hire within

the NAS. The DJI Inspire 1 is 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 approximately 6.47 lb. while having a dimension of 17.24 x 17.75

x 11.85 inches, a maximum speed of approximately 22 m/s and a maximum flying height of 400'.

The DJI Inspire 1 is equipped with four main rotors; driven by Lithium Polymer battery powered

electric motors.

3
The DJI Inspire 1 that will be operated by VENT2WIRE 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, VENT2WIRE, 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, VENT2WIRE 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, VENT2WIRE 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.

VENT2WIRE submits that the requested relief is proper since an equivalent level of safety will be

ensured. VENT2WIRE 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, VENT2WIRE will document and maintain all maintenance

records for the 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 VENT2WIRE 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 Phantom UAS in a manner consistent

with this exemption, including evasive and emergency maneuvers and maintaining appropriate

distances from people, vessels, vehicles and structures.

VENT2WIRE seeks relief from Section 91.7(a), entitled Civil aircraft airworthiness, because the

DJI Inspire 1 UAS do not require an airworthiness certificate in accordance with 14 C.F.R. Part 21,

Subpart H. As such, VENT2WIRE submits that they will ensure that the DJI Inspire 1 UAS is in an

airworthy condition, prior to every flight, by determining that the UAS are in compliance with the

operating documents (i.e., Monthly Maintenance Log, and DJI Inspire 1 Instruction Manual), and

that the aircraft are in a condition for safe flight.

VENT2WIRE 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 VENT2WIRE’s operation of the DJI Inspire 1

4
UAS within visual line of sight, at or below 400 feet AGL, will ensure a level of safety

equivalent to Section 91.121.

Additionally, VENT2WIRE seeks an exemption from the requirements of Section

91.151(b), entitled Fuel requirements for flight in VFR conditions. VENT2WIRE 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 23 minutes. Battery power

indicators are also able to show exactly how much battery power is left, as well as how

much time is needed to return safely back to point of take off.

In accordance with 14 C.F.R. § 11.81, VENT2WIRE 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:

Justin Wayoro

President 

VENT2WIRE MARKETING dba. VENT2WIRE

P.O Box 50335

Oxnard, Ca, 93033

805 263 7870

Info@vent2wire.com

5
B. The Specific Sections Of 14 C.F.R. From Which VENT2WIRE Seeks Exemption.

1. VENT2WIRE 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.

1. VENT2WIRE 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. VENT2WIRE 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

(i) 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.

1. VENT2WIRE Seeks Exemption From The Requirements Of Section 91.151(b).

6
Section 91.151, entitled Fuel requirements for flight in VFR conditions, subsection

(b), states the following:

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

(considering wind and forecast weather conditions) there is enough fuel to fly to

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

after that for at least 20 minutes.

5. VENT2WIRE 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. VENT2WIRE 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. VENT2WIRE 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. VENT2WIRE 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:

7
(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 100­hour, annual, progressive, and other required or approved

inspections, as appropriate, for each aircraft (including the airframe) and each

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

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

of the work performed; and

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

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

the aircraft for return to service.

(1) 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 life­limited parts of each airframe, engine,

propeller, rotor, and appliance.

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

which are required to be overhauled on a specified time basis.

(ii) 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.

(i) 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.

(i) 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.

(a) 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.

8
(3) A list of defects furnished to a registered owner or operator under §

43.11 of this chapter shall be retained until the defects are repaired and the

aircraft is approved for return to service.

C. The Extent Of Relief VENT2WIRE Seeks And The Reason VENT2WIRE Seeks The

Relief.

1. Extent Of Relief VENT2WIRE Seeks And The Reason VENT2WIRE 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 flight­hour 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, VENT2WIRE 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 flight­hour 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, VENT2WIRE submits that all flights of the DJI Inspire 1 UAS, conducted by the PIC

pursuant to the grant of this Petition: (1) will be incidental to VENT2WIRE’s business; and (2) will

not carry passengers or property for compensation or hire.

2. Extent Of Relief VENT2WIRE Seeks And The Reason VENT2WIRE 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 VENT2WIRE to determine that the DJI Inspire 1 UAS are in airworthy

condition prior to every flight by ensuring that the UAS is in compliance with the operating

documents (i.e., VENT2WIRE Aerial Operations Manual, Monthly Maintenance Log, and

DJI Inspire 1 Instruction Manual).

VENT2WIRE 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,

VENT2WIRE will ensure that the DJI Inspire 1 UAS are in airworthy condition based upon

its compliance with the operating documents (i.e., Monthly Maintenance Log, and DJI

Inspire 1) prior to every flight, and further, determine that the aircraft are in condition for

safe flight, as stated in the conditions and limitations below.

9
3. Extent Of Relief VENT2WIRE Seeks And The Reason VENT2WIRE Seeks Relief

From Section 91.121.

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

of the DJI Inspire 1 UAS, 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), VENT2WIRE seeks the requested relief because the DJI

Inspire 1 UA’s altimeter may be set on the ground to zero feet AGL, rather than the local

barometric pressure or field altitude, before each flight.

Considering the limited altitude of the proposed operations, relief from 14 CFR 91.121 is sought to

the extent necessary to comply with the applicable conditions and limitations stated below. As

more fully set forth herein, an equivalent level of safety will be maintained since the DJI 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 heads­up display of the GCS.

4. Extent Of Relief VENT2WIRE Seeks And The Reason VENT2WIRE 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 23 minutes. VENT2WIRE 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

VENT2WIRE proposes to conduct pursuant to this Petition.

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

Inspire 1 operating documents, and VENT2WIRE’s proposed operating limitations, ensure that

VENT2WIRE 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 23 minutes.

5. Extent Of Relief VENT2WIRE Seeks And The Reason VENT2WIRE 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, VENT2WIRE requests relief from these Sections because

the DJI Inspire 1 UAS do not require airworthiness certificates. As set forth more fully below, the

DJI Inspire 1 UAS meet the conditions of FMRA Section 333 for operation without an

airworthiness certificate. Accordingly, VENT2WIRE will use trained

10
technicians to perform maintenance, alterations, or preventive maintenance on the UAS using the

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

VENT2WIRE Aerial Operations Manual, Monthly Maintenance Log, and DJI Inspire 1 Instruction

Manual). Furthermore, VENT2WIRE will document and maintain all maintenance records for the

DJI Inspire 1 UAS.

D. The Reasons Why Granting VENT2WIRE 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 VENT2WIRE to safely,

efficiently, and economically perform aerial video and photography of construction sites, real

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

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

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

VENT2WIRE’s proposed operation of the DJI Inspire 1 UAS 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

11
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

20­30 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

2.8 pounds at their maximum gross weight with diagonal dimension of 23.2 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

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 VENT2WIRE, 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 UAS, companies such as VENT2WIRE, 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,

VENT2WIRE’s proposed operation of the DJI Inspire 1 UAS will not implicate any privacy issues.

Specifically, the DJI Inspire 1 UAS will be operated only in compliance with operating documents

(i.e., VENT2WIRE 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.

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 VENT2WIRE Seeks Exemption.

12
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, VENT2WIRE’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, VENT2WIRE 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 UAS; (b) the pilot certification requirement; and (c) the

specific operating limitations.

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

Characteristics.

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.

13
The technical specifications of the DJI Inspire 1 UAS are set forth by the DJI Inspire 1

User Manual, attached hereto as Appendix A.

ii. The DJI Inspire 1 UAS Global Positioning Modes Enable The UAS To

Remain Within A Defined Operational Area.

The DJI Inspire 1 UAS may be operated in both manual and global positioning flight modes. A

complete description of the flight and navigational modes of the DJI Inspire 1 UAS is provided at

pages 11 of the DJI Inspire 1 User Manual attached hereto as Appendix A.

iii. The DJI Inspire 1 UAS Are Designed For Automatic Return To Home Point

Or Hover In The Event Of Loss Of The Control Link Or Navigation.

When the Control Link is lost, the DJI Inspire 1 UAS will remain stationary, in flight, for 3 seconds

or more. If, after 3 seconds, the DJI Inspire 1 UAS does not reacquire control link data from the

GCS, the UAS will assume that the Control Link is lost and the 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 UAS are set forth at pages

12 through 14 of the DJI Inspire 1 User Manual, attached hereto as Appendix 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 23 through 29 of the DJI Inspire 1 User

Manual. DJI Inspire 1 User Manual is attached hereto as Appendix A.

b. Flight Operations Of DJI Inspire 1 UAS Is Limited To The Line Of Sight Of A

Certificated Pilot in Command With A Safety Observer.

14
VENT2WIRE video production staff will be the only persons to act as a pilot in command

(PIC) of the DJI Inspire 1 UAS. Additionally, a safety observer will assist him at all times

during flight time.

c. Flights Of DJI Inspire 1 UAS Will Be Conducted Pursuant To Specific Operating

Limitations.

In seeking this exemption, VENT2WIRE proposes to commercially operate 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 UAS 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.

1. The UAS may not be flown at an indicated airspeed exceeding 20 knots.

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

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

documents unless a special request is made and approved by ATC. All altitudes

reported to ATC must be in feet AGL.

2. The UAS must be operated within visual line of sight (VLOS) of the PIC at

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

device other than corrective lenses, as specified on the PIC’s FAA­issued

airman medical certificate.

3. The use of first person view (FPV) by the PIC or safety observer (SO) is

not permitted.

4. All operations must utilize a safety observer (SO). The SO may be used

to satisfy the VLOS requirement as long as the PIC always maintains VLOS

capability. The SO and PIC must be able to communicate verbally at all times.

Electronic messaging or texting is not permitted during flight operations. The

PIC must be designated before the flight and cannot transfer his or her

designation for the duration of the flight. The PIC must ensure that the SO can

perform the functions prescribed in the operating documents.

15
The SO must not perform any other duties beyond assisting the PIC with seeing and avoiding

other air traffic and other ground based obstacles/obstructions and is not permitted to operate the

camera or other instruments.

1. The operating documents and the grant of exemption must be accessible during UAS

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

the conditions and limitations contained in the grant of exemption and the procedures outlined in

the operating documents, the conditions and limitations contained in the grant of exemption take

precedence and must be followed. Otherwise, the operator must follow the procedures as outlined

in its operating documents. The operator may update or revise its operating documents. It is the

operator’s responsibility to track such revisions and present updated and revised documents to

the Administrator upon request. The operator must also present updated and revised documents

if it petitions for extension or amendment to the grant of exemption. If the operator determines that

any update or revision would affect the basis upon which the FAA granted the exemption, then

the operator must petition for amendment to its grant of exemption. The FAA’s UAS Integration

Office (AFS­80) may be contacted if questions arise regarding updates or revisions to the

operating documents.

1. Prior to each flight the PIC must inspect the UAS to ensure that it is in a condition for safe

flight. If the inspection reveals a condition that affects the safe operation of the UAS, the aircraft

is prohibited from operating until the necessary maintenance has been performed and the UAS is

found to be in a condition for safe flight. The Ground Control Station must be included in the

preflight inspection. All maintenance and alterations must be properly documented in the aircraft

records.

1. Any UAS that has undergone maintenance or alterations that affect the UAS

operation or flight characteristics, e.g. replacement of a flight critical component, must

undergo a functional test flight. The PIC who conducts the functional test flight must

make an entry in the aircraft records.

1. The pre­flight inspection must account for all potential discrepancies, e.g.

inoperable components, items, or equipment, not already covered in the relevant

sections of the operating documents.

2. The operator must follow the UAS manufacturer’s aircraft/component,

maintenance, overhaul, replacement, inspection, and life limit requirements.

3. The operator must carry out its maintenance, inspections, and record keeping requirements, in

accordance with the operating documents. Maintenance, inspection, alterations, and status of

replacement/overhaul component parts must be noted in the aircraft records, including total time in

service, description of work accomplished, and the signature of the authorized person returning

the UAS to service.

1. Each UAS operated under this exemption must comply with all manufacturer's

Safety Bulletins.

2. The authorized person must make an entry in the aircraft record of the corrective action

taken against discrepancies discovered between inspections.

3. The PIC must possess at least a private pilot certificate and at least a current

third­class medical certificate.

4. The operator may not permit any PIC to operate unless the PIC meets the operator’s

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qualification criteria and demonstrates the ability to safely operate the UAS in a manner consistent

with how the UAS will be operated under the exemption, including evasive and emergency

maneuvers and maintaining appropriate distances from persons, vessels, vehicles and structures.

PIC qualification flight hours must be logged in a manner consistent with 14 C.F.R. § 61.51(b).

Flights for the purposes of training the operator’s PICs are permitted under the terms of the

exemption. However, training operations may only be conducted during dedicated training

sessions. During training, proficiency, and experience­building flights, all persons not essential for

flight operations are considered nonparticipants, and the PIC must operate the UA with

appropriate distance from nonparticipants in accordance with 14 C.F.R. § 91.119.

5. UAS operations may not be conducted during night, as defined in 14 C.F.R. § 1.1.

All operations must be conducted under visual meteorological conditions (VMC). If flight

at night is required, a special request will be made at the FAA office closest to proposed

area of operations. Flights under special visual flight rules (SVFR) are not authorized.

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

denoted on a current FAA­published aeronautical chart unless a letter of agreement with

that airport’s management is obtained, and the operation is conducted in accordance with

a NOTAM as required by the operator’s COA. The letter of agreement with the airport

management must be made available to the Administrator upon request.

7. 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.

8. If the UA loses communications or loses its GPS signal, it must return to a

predetermined location within the planned operating area and land or be recovered in

accordance with the operating documents.

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

in accordance with the operating documents.

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

weather conditions) there is enough power to fly at normal cruising speed to the intended landing

point and land the UA with 25% battery power remaining.

3. The operator must obtain an Air Traffic Organization (ATO) issued Certificate of Waiver or

Authorization (COA) prior to conducting any operations under the grant of exemption. This COA

will also require the operator to request a Notice to Airman (NOTAM) not more than 72 hours in

advance, but not less than 48 hours prior to the operation. All operations shall be conducted in

accordance with airspace requirements in the ATO issued COA including class of airspace,

altitude level and potential transponder requirements.

4. All aircraft operated in accordance with the exemption must be identified by serial

number, registered in accordance with 14 C.F.R. part 47, and have identification

(N­Number) markings in accordance with 14 C.F.R. part 45, Subpart C. Markings must be

as large as practicable.

5. Before conducting operations, the radio frequency spectrum used for operation and control

of the UA must comply with the Federal Communications Commission (FCC) or other appropriate

government oversight agency requirements.

6. The documents required fewer than 14 C.F.R. 91.9 and 91.203 must be available

17
to the PIC at the Ground Control Station of the UAS any time the UAS is operating. These

documents must be made available to the Administrator or any law enforcement official

upon request.

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

operations and activities at all times.

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

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

persons (persons other than the PIC, SO, operator trainees or essential persons),

vessels, vehicles, and structures unless:

a. Barriers or structures are present that sufficiently protect nonparticipating persons

from the UA and/or debris in the event of an accident. The operator must ensure that

nonparticipating persons remain under such protection. If a situation arises where

nonparticipating persons leave such protection and are within 500 feet of the UA, flight

operations must cease immediately and/or;

a. The aircraft is operated near vessels, vehicles or structures where the owner/

controller of such vessels, vehicles or structures has granted permission and the PIC has

made a safety assessment of the risk of operating closer to those objects and determined

that it does not present an undue hazard, and;

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

do not present an undue hazard to those persons per § 91.119(a).

1. All operations shall be conducted over private or controlled­access

property with permission from the land owner/controller or authorized

representative. Permission from land owner/controller or authorized

representative will be obtained for each flight to be conducted.

1. 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 (AFS­80) 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.

VENT2WIRE 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 flight­hour 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 VENT2WIRE’s proposed area of operations, and the operating limitations set

forth­above; the parallel nature of private pilot aeronautical knowledge requirements to

those of commercial pilot requirements (See Exemption No. 11062); and the airmanship

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skills necessary to safely operate the DJI Inspire 1 UAS, VENT2WIRE submits that the

additional manned airmanship experience of a commercially certificated pilot would not

correlate to the airmanship skills necessary for VENT2WIRE’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).

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VENT2WIRE will not allow any PIC to operate the DJI Inspire 1 UAS unless that PIC has

demonstrated, by meeting minimum flight­hour 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 VENT2WIRE’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 multi­rotor 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 multi­rotor time and the 10 hours may be

included in the total 25 hours of UAS rotorcraft time. In addition to the hour requirements,

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

purposes). The FAA finds that at a minimum, the 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 experience­building flights can also be

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

training, proficiency, and experience­building 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.

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Accordingly, VENT2WIRE will ensure safe operations by not allowing any PIC to operate the DJI

Inspire 1 UAS unless that PIC has demonstrated, by meeting minimum flight­hour 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, VENT2WIRE 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 VENT2WIRE’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 UAS at ground level.

The FAA has previously granted relief from Section 91.121 specific to UAS, in

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

Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11112, 11136, 11138,

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

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

Not Adversely Affect Safety.

21
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

UAS; (2) the limitations on the proposed flight operations; and (3) the location of the

proposed flight operations. Accordingly, VENT2WIRE 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 23 minutes.

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

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 UAS 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 UAS 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, VENT2WIRE 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 VENT2WIRE will use

trained technicians to perform maintenance, alterations, or preventive maintenance on the UAS

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

VENT2WIRE Aerial Operations Manual, Monthly Maintenance Log, and DJI Inspire 1 Instruction

Manual). Furthermore, VENT2WIRE will document and maintain all maintenance records for the

DJI Inspire 1 UAS.

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

VENT2WIRE will maintain the equivalent level of safety established by Sections 91.405(a),

91.409(a)(1), and 91.409(a)(2). A copy of the DJI Inspire 1 User Manuals are attached hereto as

Appendix A and B; a copy of the DJI Inspire 1 UAS Maintenance LOG is attached hereto

as Appendix C.

Likewise, the exemption sought will not adversely affect safety because VENT2WIRE 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.

22
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 UAS 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 VENT2WIRE’s proposed operating limitations, the operating documents, and the technical

aspects of the DJI Inspire 1 UAS, VENT2WIRE 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, VENT2WIRE 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:

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)

23
& (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 VENT2WIRE Seeks Exemption:

VENT2WIRE 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 VENT2WIRE Seeks:

This exemption will permit VENT2WIRE 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

VENT2WIRE’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, VENT2WIRE’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, VENT2WIRE 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.

CONCLUSION

As set forth herein, VENT2WIRE 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 VENT2WIRE 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, VENT2WIRE respectfully requests

that the Administrator grant this Petition for an exemption from the requirements of 14

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

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

24
Inspire 1 UAS commercially for the purpose of conducting aerial video and photography

over certain areas of the United States.

Dated: December 1, 2015

Respectfully submitted,

Justin Wayoro

President 

Vent2wire Marketing dba. VENT2WIRE

P.O Box 50335

Oxnard, Ca, 93033

Info@vent2wire.com

Appendices:

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A – Link to DJI Inspire 1 Manual: Click on link below

http://download.dji­innovations.com/downloads/inspire_1/en/Inspire_1_User_Manual_v1.4_en.pdf

B ­ Link to DJI Inspire 1 Maintenance Manual: Click on the link below

h t t p : / / d o w n l o a d . d j i ­ i n n o v a t i o n s . c o m / d o w n l o a d s / i n s p i r e _ 1 / e n /

Inspire_1_Maintenance_ManualV1.0_en.pdf

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