U.S. Department of Transportation, Docket Operations

West Building Ground Floor, Room w12B140

1200 New Jersey Avenue. S.E.

Washington, DC 20590

IN THE MATTER OF THE PETITION FOR EXEMPTION OF:

HI Perspective Media Group LLC

FOR A SUMMARY GRANT EXEMPTION SEEKING RELIEF FROM THE 

REQUIREMENTS OF

TITLE 14 OF THE CODE OF FEDERAL REGULATIONS

PART 21, SUBPART H AND SECTIONS 61.23(a) & (c), 61.101(e) (4) & (5), 61.113(a), 

61.315(a),

91.7(a), 91.9(b) (2), 91.103, 91.119(c), 91.121, 91.151(a) (1), 91.405(a), 91.407(a)(1),

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

OPERATION OF DJI PHANTOM 2,

DJI PHANTOM 3, DJI INSPIRE 1, DJI S900 AND DJI S1000 UNMANNED AIRCRAFT 

SYSTEMS

PURSUANT TO SECTION 333 OF THE

FAA MODERNIZATION AND REFORM ACT OF 2012

(PUBLIC LAW 112-95)

Submitted on September 15, 2015

HI Perspective Media Group LLC's

368 S Kalaheo Ave.

Kailua HI 96734

808-266-0618

e-mail: HIperspectivemedia@gmail.com
I. SUMMARY

Pursuant to Section 333 of FMRA, HI Perspective Media Group LLC's (“HI Perspective” 

or "Operator"), hereby applies for an exemption from the following listed FARs to operate its 

sUASs for commercial purposes:

14 C.F.R. Part 21, Subpart H

14 C.F.R § 45.23

14 C.F.R. § 45.27(a)

14 C.F.R. § 61.23 (a) & (c)

14 C.F.R. § 61.101 (e) (4) & (5)

14 C.F.R. § 61.113 (a)

14 C.F.R. § 61.315 (a)

14. C.F.R. § 91.7 (a)

14 C.F.R. §91.9 (b) (2)

14 C.F.R. §91.103

14 C.F.R. §91.119 (c)

14. C.F.R. §91.121

14. C.F.R. §91.151 (a) (1)

14. C.F.R. §91.405 (a)

14. C.F.R. §91.407 (a) (1)

14. C.F.R. §91.409 (a) (1) & (a)(2)

14. C.F.R. §91.417 (a) & (b)

This exemption will allow to HI Perspective Media Group LLC employ its sUASs to lead 

the way in capturing new perspectives that benefit various fields. These operations will be 

conducted within and under the conditions outlined herein, or as may be established by the FAA 

as required by Section 333 of FMRA.
As described in greater detail below, the requested exemption would permit the operation 

of a sUAS at or below 400 feet AGL, under controlled conditions in airspace that (1) is limited; 

(2) is predetermined; (3) is controlled as to access; and (4) provides safe operations. No 

operations will be conducted over restricted airspace or over congested areas. Approval of this 

exemption would enhance safety, promote industry growth and fair competition through 

increased affordability of aerial photography and videography, and would fulfill the Secretary of 

Transportation’s responsibilities to establish requirements for the safe operation of such aircraft 

systems in the NAS pursuant to Section 333 of FMRA.

II. INTRODUCTION AND INTERESTS OF THE PETITIONER

HI Perspective Media Group LLC is a complete media source capturing new perspectives 

from all angles in industries such as but not limited to; motion picture, webcast and television, 

real estate, short range inspections, scientific research, mapping and surveying, agricultural,

search and rescue, industrial/construction sites, increase public knowledge of sUAS and promote 

safe sUAS operations.

 

III. BACKGROUND ON HI Perspective Media Group LLC'S sUASs

HI Perspective seeks an emption to operate its five sUASs for compensation or hire 

within the NAS for aerial photography and videography. HI Perspective will operate its sUASs 

in line of sight and within a closed-off, predetermined area with written and/or oral permission 

from the relevant property owners and in accordance with applicable local law. HI Perspective’s 

sUASs have the following operational characteristics:

 The DJI Phantom 2 operates at a maximum flight speed of 15m/s;

 The DJI Phantom 3 operates at a maximum flight speed of 16 m/s

 The DJI Inspire 1 operates a maximum flight speed of 22 m/s; 

 The DJI S900 operates at a maximum flight speed of 18 m/s

 The DJI S1000 operates at a maximum flight speed of 20 m/s

 Each of HI Perspective’s sUASs is a vertical takeoff and landing sUAS with a ground 

 control station utilizing electronic tablet or smart phone systems; 

 

  Each of HI Perspective’s sUASs has the capability to hover, and move in the vertical 

 and horizontal plane simultaneously; 

 HI Perspective’s Phantom 2 is a vertical takeoff and landing (VTOL) Unmanned 

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

control systems. The DJI Phantom 2 has a maximum gross weight of approximately 2 
pounds 11 ounces, while having a length of 16 inches width of 16 inches, height of 8 

inches, and a maximum speed of approximately 29 knots. The DJI Phantom 2 is 

equipped with four main rotors; driven by Lithium Polymer battery powered electric 

motors. The DJI Phantom 2 that will be operated by HI Perspective 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.

 http://download.djiinnovations.com/downloads/phantom_2_vision_plus/en/Phantom_2_Vision_P

lus_User_Manual_v1.8_en.pdf http://download.djiinnovations.com/downloads/phantom_2_vision_plus/en/Phantom_2_Vision_P

lus_Quick_Start_Guide_en.pdf

 HI Perspective’s Phantom 3 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 Phantom 3 has a maximum gross weight of 

approximately 2.8 pounds, while having a length of 16 inches width of 16 inches, 

height of 8.5 inches, and a maximum speed of approximately 31 knots. The DJI 

Phantom 3 is equipped with four main rotors; driven by Lithium Polymer battery 

powered electric motors. The DJI Phantom 3 that will be operated by HI Perspective 

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.

 http://download.djiinnovations.com/downloads/phantom_3/en/Phantom_3_Professional_User_M

anual_v1.4_en.pdf http://download.djiinnovations.com/downloads/phantom_3/en/Phantom_3_Professional_Quick_

Start_Guide_en_v1.2.pdf

 HI Perspective’s Inspire 1 is a vertical takeoff and landing (VTOL) Unmanned 

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

control systems. The DJI Inspire 1 has a maximum gross weight of approximately 6

pounds 7.5 ounces, while having a length of 17.3 inches width of 17.7 inches, height 

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

equipped with four main rotors; driven by Lithium Polymer battery powered electric 

motors. The DJI Inspire 1 that will be operated by HI Perspective 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.

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

f , http://download.dji-
innovations.com/downloads/inspire_1/en/Inspire_1_Quick_Start_Guide_v1.4_

en.pdf

 HI Perspective’s S900 is a vertical takeoff and landing (VTOL) Unmanned Aircraft 

(UA) with a Ground Control Station (GCS) utilizing electronic remote control 

systems. The DJI S900 has a maximum gross weight of approximately 18 pounds, 

while having a length of 35 inches width of 35 inches, height of 14 inches, and a 

maximum speed of approximately 35 knots. The DJI S900 is equipped with six main 

rotors; driven by Lithium Polymer battery powered electric motors. The DJI S900 

that will be operated by HI Perspective 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.

 http://download.djiinnovations.com/downloads/s900/en/S900_User_Manual_v1.0_en.pdf

 HI Perspective’s S1000 is a vertical takeoff and landing (VTOL) Unmanned Aircraft 

(UA) with a Ground Control Station (GCS) utilizing electronic remote control 

systems. The DJI S1000 has a maximum gross weight of approximately 25 pounds, 

while having a length of 41 inches width of 41 inches, height of 14 inches, and a 

maximum speed of approximately 39 knots. The DJI S1000 is equipped with eight 

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

Phantom 3 that will be operated by HI Perspective 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.

 http://download.djiinnovations.com/downloads/s1000/en/S1000_User_Manual_v1.00_en.pdf

Petitioner’s proposed use will have flight times of a maximum of 20 minutes, allowing 

HI Perspective to properly staff small flight areas, and to have ample time to control each sUAS 

to a safe landing zone. HI Perspective’s sUASs are the type of lightweight sUAS expressly 

contemplated by FMRA. Each of HI Perspective’s sUASs, including payload, is far below the 55 

pound sUAS classification requirement, and one is also below the 4.4 pound requirement 

developed by the proposed 14 C.F.R. Part 107 that creates the “microUAS” subclass of sUAS.

HI Perspective’s sUASs will be operated by trained professionals and 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, subject to the exemption requested below.
No operations will be conducted in restricted airspace or over congested areas, and, if 

required, and all other operations will be conducted only with FAA ATC permission or as 

otherwise stipulated by the FAA. In addition, the maximum altitude for any operation will not 

exceed 400 feet above ground level. Operations will only be conducted in daylight and within 

visual line of sight. Additionally, HI Perspective's sUASs will not be operated within five (5) 

nautical miles of any airport, and notice will be given to the local Flight Service District Office 

(FDSO) prior to flight operations.

IV. BASIS FOR PETITION

A. SUMMARY 

Petitioner, HI Perspective Media Group LLC, pursuant to the provisions of the FARs (14 

C.F.R §11.61) and FMRA, Section 333, Special Rules for Certain Unmanned Aircraft Systems, 

hereby petitions the Administrator to operate commercially the sUASs described above in the 

NAS, and for an exemption from the requirements of the following: 14 C.F.R. Part 21, Subpart 

H, and 14 C.F.R. Sections §§ 45.23, 45.27(a), 61.23(a) & (c), 61.101(e)(4) & (5), 61.113(a), 

61.315(a), 91.7(a), 91.9(b)(2), 91.103, 91.119(c), 91.121, 91.151(a)(1), 91.405(a), 91.407(a)(1), 

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

This exemption application is expressly submitted to fulfill the legislative goals set forth 

in Section 333 of FMRA. This law directs the Secretary of Transportation to consider whether 

certain unmanned aircraft systems may operate safely in the NAS before completion of the 

rulemaking required under Section 332 of the Reform Act. In making this determination, the 

Secretary of Transportation is required to determine which types of sUASs do not create a hazard 

to users of the NAS or the public, or pose a threat to national security. HI Perspective’s operation 

of its sUASs will meet the conditions of FMRA's Section 333 given (1) the size, weight, speed 

and operational capability of HI Perspective's sUASs; (2) the operation of HI Perspective's

sUASs away from airports and in a limited operating area; and (3) the operation of HI

Perspective's sUASs within visual line of sight of the Operator. 

Accordingly, HI Perspective seeks relief inter alia from the following: 

(1) Section 91.7(a), entitled Civil Aircraft Airworthiness. Given that HI Perspective's

sUASs meets the requirements of Section 333, HI Perspective will not require an airworthiness 

certificate in accordance with 14 C.F.R. Part 21, Subpart H, and hence HI Perspective requests 

relief from Section 91.7(a). HI Perspective will ensure that each of HI Perspective’s sUASs is in 

an airworthy condition, prior to every flight, by determining that it’s in compliance with the 

applicable Operating Documents, and that each sUASs is in a condition for safe flights; 

(2) Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2) and 91.417(a) & (b), 

entitled Maintenance Required, Operation after Maintenance, Preventative Maintenance, 

Rebuilding or Alteration, Inspection and Maintenance Records, respectively. Relief is requested 

from these sections as they set forth requirements for maintenance that only apply to aircraft with 

an airworthiness certificate. HI Perspective submits that the requested relief is proper since an 

equivalent level of safety will be ensured. HI Perspective will use experienced personnel or 
technicians to perform maintenance, alterations, or preventive maintenance on its sUASs using 

methods, techniques and practices prescribed in the Operating Documents. Furthermore, HI 

Perspective will document and maintain all maintenance records for its sUASs; 

(3) Sections 61.23(a) & (c), entitled Medical Certificates: Requirement and Duration. 

Relief is requested from this section as the FAA has announced in a Press Release dated April 9, 

2015 that medical certification will no longer be required to operate sUAS. 

(4) Certain requirements of Sections 61.101(e)(4) & (5), 61.113, and 61.315, entitled 

Recreational Pilot Privileges and Limitations, Private Pilot Privileges and Limitations: Pilot in 

Command, What are the Privileges and Limitations of my Sports Pilot Certificate? Relief is 

requested from these Sections to the extent necessary to allow a PIC to operate HI Perspective's

sUASs, provided such PIC (a) holds a Recreational or Sports Pilot (or higher level) certificate, 

(b) holds a valid U. S. drivers license, and (c) has demonstrated that he/she is able to operate 

safely HI Perspective’s sUASs in a manner consistent with this exemption, including evasive and 

emergency maneuvers and maintaining appropriate distance from people, vessel, vehicles and 

structures. In addition, relief is requested as it is the Operator’s intent to operate its sUASs for 

compensation or hire and in furtherance of a business. 

(5) Section 91.121, entitled Altimeter Settings. Relief is requested as HI Perspective’s 

sUASs will not have a typical barometric altimeter onboard. However, altitude information of HI 

Perspective’s sUASs will be provided to the PIC via Global Positioning System (GPS) 

equipment and radio communications telemetry data link, which downlinks from each sUAS to 

the GCS for active monitoring of the flight path. This altitude information, combined with HI 

Perspective’s operation of its sUASs within visual line of sight and at or below 400 feet AGL, 

will ensure a level of safety equivalent to Section 91.121. 

(6) Section 91.151(b), entitled Fuel Requirements for Flight in VFR Conditions. 

Relief is requested as HI Perspective submits that safety will not be affected by the operation of 

its sUASs during daylight hours in visual meteorological conditions (VCM) under visual flights 

rules (VFR), with enough battery power to fly for a total duration of approximately 15 minutes to 

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

least 5 minutes. 

B. SUPPORT FOR THE PETITION FOR EXEMPTION

In accordance with 14 C.F.R. § 11.81 (a)-(f), HI Perspective 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 are: 

The name and address of the applicant is:

HI Perspective Media Group LLC.
368 S. Kalaheo Ave.

Kailua, Hawaii 96734

808-266-0618

HIperspectivemedia@gmail.com.

The point of contact for this Petition and specific contact information is: 

Chance Trent

368 S. Kalaheo Ave. 

Kailua, Hawaii 96734 

808-266-0618

chance.trent@yahoo.com

(b) Specific Sections of 14 C.F.R from which HI Perspective seeks exemption: 

(1) 14 C.F.R. Part 21 Subpart H and 14 C.F.R § 91.203(a)(1) and (b): 

Subpart H of 14 C.F.R. Part 21, entitled Airworthiness Certificates, establishes the 

procedural requirements for the issuance of airworthiness certificates as required by 14 

C.F.R. § 91.203(a)(1) and (b). 

(2) 14 C.F.R. §§ 45.23 and 45.27(a), entitled Display of Marks, general and Location 

of marks; non-fixed-wing aircraft, respectively, establishes the regulatory requirements 

for the identification of aircraft including US registration requirements and size. 

(3) 14 C.F.R. § 61.23(a) & (c): 

14 C.F.R. § 61.23(a) & (c), entitled Medical Certificates: Requirement and Duration

establishes the medical certification required for various categories of pilot certification 

and/or aircraft operation. 

(4) 14 C.F.R. § 61.101(e)(4) & (5): 

Pursuant to 14 C.F.R. §61.101(e)(3),(4)&(5), entitled Recreational Pilot Privileges and 

Limitations, no person holding a recreational pilot certification can act as PIC of an 

aircraft that is operated for compensation or hire or in furtherance of a business. 

(5) 14 C.F.R. § 61.113(a): 

Pursuant to 14 C.F.R. § 61.113(a), entitled Private Pilot Privileges & Limitations, no 

person who holds a private pilot certificate may act as a pilot in command of an aircraft 

that is carrying passengers or property for compensation or hire, nor may that person, for 

compensation or hire, act as pilot in command of an aircraft. 

(6) 14 C.F.R. § 61.315(a): 
Pursuant to 14 C.F.R. § 61.315, entitled What are the Privileges and Limits of my Sport 

Pilot Certificate?, no person holding a Sport Pilot Certificate can act as a PIC of a light 

sport aircraft that is operated for compensation or hire or in furtherance of a business. 

(7) 14 C.F.R. § 91.7(a):

Pursuant to 14 C.F.R. § 91.7 (a), entitled Civil Aircraft Airworthiness, no person may 

operate a civil aircraft unless it is in airworthy condition. As there will be no 

airworthiness certificate issued for HI Perspective's sUASs, should this exemption be 

granted, no FAA regulatory standard will exist for determining airworthiness. 

(8) 14 C.F.R. § 91.9(b)(2): 

Section 91.9 (b) (2), entitled Civil Aircraft Flight Manual in the Aircraft, provides: "No person 

may operate a U.S.-registered civil aircraft ... (2) For which an Airplane or Rotorcraft Flight 

Manual is not required by § 21.5 of this chapter, unless there is available in the aircraft a current 

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

placards, or any combination thereof." 

(9) 14 C.F.R. § 91.103: 

Section 91.103, entitled Preflight Action requires each PIC to take certain actions before 

flight to insure the safety of flight. 

(10) 14 C.F.R. §91.119: 

Section 91.119, entitled Minimum Safe Altitudes, establishes safe altitudes for operation 

of civil aircraft. 

(11) 14 C.F.R. §91.121: 

Section 91.121, entitled Altimeter Settings, requires each person operating an aircraft to 

maintain cruising altitude by reference to an altimeter that is set “...to the elevation of the 

departure airport or an appropriate altimeter setting available before departure.” 

(12) 14 C.F.R. § 91.151(a):

Section 91.151(a), entitled Fuel Requirements for Flight in VFR Conditions, prohibits an 

individual from beginning “a flight in an airplane under VFR conditions unless 

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

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

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

(2) At night, to fly after that for at least 45 minutes.” 

(13) 14 C.F.R. §91.405(a); 407(a)(1); 409(a)(1) & (2); 417(a) & (b): 
These regulations, respectively entitled Maintenance Required, Operation after 

Maintenance, Preventive Maintenance, Rebuilding or Alternation, Inspections, and 

Maintenance Records, require, inter alia, that an aircraft operator or owner “shall have 

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

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

repaired as prescribed in part 43 of this chapter...,” and others shall inspect or maintain 

the aircraft in compliance with Part 43.

(c) The Extent of Relief HI Perspective Seeks and the Reason HI Perspective Seeks the 

Relief

(1) Extent of Relief HI Perspective Seeks and the Reason HI Perspective Seeks Relief 

from 14 C.F.R. Part 21, Subpart H and 14 C.F.R § 91.203(a)(1) and (b): Airworthiness 

Certificates. 

HI Perspective requests exemption from the requirements for an airworthiness certificate, 

pursuant to 49 U.S.C. § 44701(f) and Section 333 of FMRA. Given the size and limited 

operating area associated with the aircraft to be utilized by HI Perspective, an exemption 

from Part 21, Subpart H meets the requirements of an equivalent level of safety under 

Part 11 and Section 333 of the FMRA. The FAA is authorized to exempt aircraft from the 

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

operational capability, and proximity to airports and populated areas. In all cases, an 

analysis of these criteria demonstrates that HI Perspective's sUASs can be operated 

without an airworthiness certificate, in a restricted environment, and under the conditions 

proposed which will be at least as safe, or safer, than a conventional aircraft operating 

with an airworthiness certificate without the restrictions and conditions proposed. 

(2) Extent of Relief HI Perspective Seeks and the Reason HI Perspective Seeks relief 

from 14 C.F.R. Sections 45.23 and 45.27(a): Display of Marks, general and Location of marks; 

non-fixed-wing aircraft, 

Given the size of HI Perspective's sUASs two inch lettering will be impossible. HI

Perspective's sUASs will be identified by serial number, registered in accordance with 14 

C.F.R. Part 47, and will have identification numbers ("N" numbers) markings in 

accordance with 14 C.F.R. Part 45, subpart C, subject to 14 C.F.R. 45.29(f), which allows 

markings to be as large as is practicable. 

(3), (4) (5) & (6) Extent of Relief HI Perspective Seeks and the Reason HI Perspective

Seeks Relief from Sections 61.23(a) & (c), 61.101(e)(4) & (5), 61.315(a) and 61.113(a): 

Medical Certificates: Requirement and Duration; Recreational Pilot Privileges and 

Limitations; Private Pilot Privileges and Limitations: Pilot in Command; What are the 

Privileges and Limitations of my Sports Pilot Certificate? 

Relief from the Sections listed above is requested to the extent necessary to allow, in 

accordance with the FAA Press Release issued on April 9, 2015, the PIC of a sUAS to 

hold a Recreational or Sports Pilot Certification, and a valid U.S. drivers license only, not 
a medical certificate. Further, relief is requested to operate such sUAS for compensation 

or hire and in the furtherance of a business. 

HI Perspective's sUASs do not carry any pilots, passengers, or property. Therefore, an 

exemption is appropriate. Although helpful, a private pilot’s license will not ensure 

remote control piloting skills. The training and knowledge required for pilots of 

conventional aircraft would not necessarily make such pilots safe to operate a sUAS. 

Moreover, the risks attendant to the operation of a sUAS are far less than the risk levels 

inherent in the commercial activities outlined in 14 C.F.R. § 61. 

As set forth more fully below, HI Perspective submits that an equivalent level of safety 

will be maintained because no PIC will be allowed to operate any of HI Perspective’s 

sUASs unless that PIC has demonstrated that he/she is able to safely operate the sUASs 

in a manner consistent with the operations specifications as described in this Petition, 

including evasive and emergency maneuvers, as well as maintaining appropriate 

distances from people, vessels, vehicles and structures. Further, HI Perspective submits 

that all flights of its sUASs, conducted by the PIC pursuant to the grant of this Petition: 

(a) will be incidental to HI Perspective’s business; and (b) will not carry passengers or

property for compensation or hire. 

HI Perspective believes that though sUAS are not traditional aircraft, a PIC operating the 

UA must have knowledge of airman and airspace rules and must comply with all the 

rules proposed by the FAA. In addition, HI Perspective’s PICs will operate its sUASs no 

higher than 400 AGL, consequently causing no danger to any other aircraft in the NAS. 

(7) Extent of Relief HI Perspective Seeks and the Reason HI Perspective Seeks Relief 

from Section 91.7(a): Civil Aircraft Airworthiness

Relief from Section 91.7(a) is requested to the extent to allow HI Perspective to 

determine that its sUASs are in airworthy condition prior to every flight by ensuring that 

its sUASs are in compliance with the Operating Documents. HI Perspective seeks the 

requested relief because its sUASs do not require an airworthiness certificate in 

accordance with 14 C.F.R. Part 21, Subpart H. HI Perspective will ensure that HI

Perspective’s sUASs are in an airworthy condition, prior to every flight, by determining 

that each such sUAS is in compliance with its applicable Operating Documents, and that 

each such sUAS is in a condition for safe flights; 

Therefore, HI Perspective will ensure that each of its sUASs is in an airworthy condition 

based upon its compliance with the Operating Documents prior to every flight, and 

further, HI Perspective will determine that each of its sUASs is in condition for safe 

flight, as stated in the conditions and limitations below. 

(8) Extent of Relief HI Perspective Seeks and the Reason HI Perspective Seeks Relief 

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

Each of HI Perspective's sUASs, given its respective size and configuration, has no 

ability or place to carry such a flight manual or placards on the aircraft, not only because 
there is no pilot on board, but also because there is no room or capacity to carry such an

item on the aircraft. The equivalent level of safety will be maintained by keeping the 

flight manual at the ground control point where the PIC flying the applicable sUAS will 

have immediate access to it. 

(9) Extent of Relief HI Perspective Seeks and the Reason HI Perspective Seeks Relief 

from 14 C.F.R. § 91.103: Preflight Action

As FAA-approved aircraft or rotorcraft flight manuals will not be provided for HI

Perspective’s sUASs, an exemption will be needed. The PIC will take all actions, 

including reviewing weather, flight battery requirements, landing and takeoff distances 

and aircraft performance data, before the initiation of any flight. 

(10) Extent of Relief HI Perspective Seeks and the Reason HI Perspective Seeks 

Relief from 14 C.F.R. §91.119(c): Minimum Safe Altitudes.

HI Perspective seeks an exemption from this section, as flight operations will always be 

at or below four hundred (400) feet AGL. An equivalent level of safety will be achieved 

by: (a) pre-flight planning, (b) communication with the local ATC and the local FSDO, 

(c) securing the flight area to prevent the public from entering, (d) briefing all crew on 

emergency procedures, (e) operating only with visual line of sight and during the 

daylight, and (f) ensuring operation of aircraft safety systems. Protections equivalent to 

minimum safe altitudes are created because, in the event of low-battery power, loss of 

communication or interference with communication between the remote control and the 

aircraft, on-board safety programs will automatically land the sUAS at a predetermined 

safe area. Similarly, the operational environment will be controlled to keep out the public.

In addition, each of HI Perspective's sUASs will have a total rotor area of less than two 

(2) feet, and will weigh equal to or less than 6.7 pounds. As such, the risk to persons and 

property is drastically reduced. Further, HI Perspective’s sUASs will not carry fuel, 

flammable material, or hazardous cargo that would pose a hazard to persons on the 

ground. 

(11) Extent of Relief HI Perspective Seeks and the Reason HI Perspective Seeks Relief 

from Section 91.121: Altimeter Settings

Relief from Section 91.121 is required to allow flight operations of HI Perspective’s 

sUASs, which utilize a barometric pressure sensor, GPS equipment and a radio 

communications telemetry data link to downlink altitude information from the sUAS to 

the PIC at the GCS. This system will automatically ensures that a ground level pressure 

setting will be established prior to each flight, and provides the PIC with altitude 

information of the sUAS on the heads-up display of the GCS. Since the FAA requires 

that any altitude information concerning sUAS operations be reported to air traffic 

control (ATC) in feet above ground level (AGL), HI Perspective seeks the requested 

relief because its sUASs 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 C.F.R. 91.121 is sought to the extent 

necessary to comply with the applicable conditions and limitations stated below. In this 

manner an equivalent level of safety will be maintained. 

An exemption is also sought as HI Perspective’s sUASs is manufactured without an 

altimeter or two-way communications radio, and there is no one aboard to read the 

altimeter. An equivalent level of safety is achieved through on-board systems and GPS 

sensors coupled with a geomagnetic compass to act as a barometric altimeter for stability 

and accuracy of flight. Information about the height of HI Perspective’s sUASs above 

ground level is displayed to the PIC at all times. 

(12) Extent of Relief HI Perspective Seeks and the Reason HI Perspective Seeks Relief 

from Section 91.151(a)(1): Fuel Requirements for Flight in VFR Conditions

Relief from Section 91.151(a)(1) is requested to the extent required to allow flights of the 

battery powered sUAS during daylight hours in visual meteorological conditions (VMC), 

under visual flight rules (VFR), for a total duration of 15 minutes to the first point of 

intended landing and, assuming normal cruising speed, to fly after that for at least 5 

minutes. HI Perspective seeks the requested relief because without an exemption from 

Section 91.151(a)(1), the flight time duration of the battery powered sUASs will severely

constrain the practicality of any aerial video or photographic flight operations that HI

Perspective proposes to conduct pursuant to this Petition. Significantly, as set forth 

below, the technical specifications of HI Perspective’s sUASs, the Operating Documents, 

and HI Perspective’s proposed operating limitations, ensure that HI Perspective will 

safely operate its sUASs. 

(13) Extent of Relief HI Perspective Seeks and the Reason HI Perspective Seeks 

Relief from Section 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.471(a) & (b): 

Maintenance Required, Operation after Maintenance, Preventive Maintenance, 

Rebuilding or Alternation, Inspections, and Maintenance Records 

Since Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.471(a) & (b) only 

apply to aircraft with an airworthiness certificate, HI Perspective requests relief from 

these Sections because its sUASs will not require an airworthiness certificate. As set forth 

more fully below, HI Perspective’s sUASs meet the conditions of FMRA Section 333 for 

operation without an airworthiness certificate. In addition, HI Perspective will use trained 

technicians to perform maintenance, alterations, or preventative maintenance on its

sUASs using the methods, techniques and practices prescribed in its sUASs Operating 

Documents. Furthermore, HI Perspective will document and maintain all maintenance 

records for its sUASs. Given that these sections and Part 43 apply only to aircraft with an 

airworthiness certificate, these sections will not apply to HI Perspective's sUASs. 

Maintenance will be accomplished by HI Perspective pursuant to the Operating 

Documents. 

Additionally, an equivalent level of safety will be achieved because these sUASs are very

limited in size, will carry a small payload and will operate only in restricted areas for 

limited periods of time. If mechanical issues arise the sUASs can land immediately, and 
will be operating from no higher than 400 feet AGL. HI Perspective will also ensure that 

its sUASs (a) are in working order prior to initiating flight, (b) are maintained as required 

by the Operating Documents, and (c) each shall have a log of any maintenance 

performed. 

(d) Granting HI Perspectives Exemption Requests would be in the Public Interest

(1) Increased Competition:

Granting this Petition furthers the public interest by safely allowing HI Perspective to 

efficiently and economically perform aerial photography and videography for its clients. 

This exemption benefits the public by expanding the use of aerial photography and 

videography by making such services available to a greater number of businesses, public 

entities and private persons. Aerial photography and videography through sUAS is safer, 

more affordable, less time-restrictive than through more conventional methods. For 

small-budget clients, the significant expense associated with aerial photography or 

videography makes such ventures unrealistic financially. Only large companies can 

generally afford to absorb such expenses. The use of sUAS to achieve aerial photographic 

objectives is much more fiscally reasonable, and creates opportunities for a wide range of 

clients to use HI Perspective (and other companies) for their aerial photography or 

videography needs. This can only have a beneficial economic impact. 

(2) The Public Will Benefit from Decreased Congestion of the NAS. 

HI Perspective’s sUASs are battery powered, and serve as a safe, efficient, and 

economical alternative to the manned aircraft traditionally utilized to obtain aerial 

photography or videography. By reducing the amount of manned aircraft needed to 

perform aerial photography or videography, an exemption allowing the use of HI

Perspective’s sUASs 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. HI 

Perspective’s sUASs 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. 

(3) The Public Will Benefit from the Safety and Efficiency of HI Perspective’s sUAS. 

Conducting aerial photography and videography with HI Perspective’s sUASs and others 

like it, 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 

photography flight operations. By using battery power and electric motors, HI

Perspective’s sUASs produce no air pollution, and are the most viable environmentally

conscious alternative to the 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. HI Perspective’s sUASs, and others like them, 

while reducing the carbon footprint of aerial photography or videography, also eliminate 

noise pollution, as such sUASs are propelled by battery powered electric motors, rather 

than an internal combustion engine. Finally, by using sUAS such as HI Perspective’s to 

perform aerial photography or videography, 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, HI Perspective’s sUASs have 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). 

(4) Performing Aerial Video and Photography Operations with HI Perspective’s sUAS 

Will Benefit the Economy. 

In addition to being safe and efficient, HI Perspective’s sUASs are also an economical 

alternative to using manned aircraft to conduct similar aerial operations. As such, 

operation by HI Perspective of its sUASs will allow small United States based 

companies, like HI Perspective’s, 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 battery powered sUAS, such as HI Perspective’s, 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 its sUASs, companies, such as HI Perspective’s, 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 such sUAS, 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. 

(5) There are No Privacy Issues.

Similar to the manned aerial photography and videography flight operations that have 

been conducted for decades, HI Perspective’s proposed operation of its sUASs will not 

implicate any privacy issues. Specifically, HI Perspective’s sUASs will be operated only 

in compliance with its Operating Documents, which requires property owner involvement 

as well as local law enforcement notification, and in accordance with the Federal 

Aviation Regulations and applicable local law. 
(e) Granting HI Perspective’s Exemption Requests would Not Adversely Affect Safety

(1) Summary. 

Given the small size of HI Perspective’s sUASs, and the controlled environment 

provided, HI Perspective’s proposed operations will adhere to FMRA’s safety 

requirements. By moving aerial photography and videography to sUAS, the potential for 

loss of life or property is greatly diminished due to the increased control of smaller, 

slower, safer aircraft that holds no persons. This enhanced maneuverability allows an 

operator to safely and quickly avoid hazards in the airspace. Utilizing sUAS minimizes 

the requirement for conventional aircraft, which benefits the public and provides a greater 

level of safety. This also decreases pollution and other detrimental environmental effects 

caused by operating combustible fuel-based, large-scale aircraft for areal photography 

and videography purposes. Emissions and noise are drastically reduced. 

The use of HI Perspective’s sUASs also eliminates the need for an onboard pilot and 

crew, and time-consuming adherence to regulations surrounding bookkeeping and 

submission of flight paths to local airports. Furthermore, the consequences of a 

lightweight sUAS crashing are obviously drastically less than those that would result 

from a full-size helicopter or fixed-wing aircraft. It is not unrealistic to project that 

crashing a 6.7 pound sUAS would cause only minimal damage. The sUASs to be 

operated hereunder are equal to or less than 6.7 pounds fully loaded, carry neither a pilot 

nor passenger, and operate exclusively within a secured and designated area. HI 

Perspective’s proposed operations under this exemption will be tightly controlled and 

monitored by HI Perspective, and under the requirements and in compliance with FAA 

and local public safety requirements. The maximum altitude for any operation will not 

exceed 400 feet AGL. Operations will only be conducted in daylight and within visual 

line of sight. These safety enhancements provide a greater degree of safety to the public 

and property owners than conventional operations conducted with airworthiness 

certificates issued under 14 C.F.R. Part 21, Subpart H. Finally, the aircraft will not be 

operated within five (5) nautical miles of any airport, and appropriate notice will be given 

to the local Flight Service District Office (FSDO) prior to flight operations. 

Given the diminutive size and weight of HI Perspective’s sUASs, combined with their 

operation in well-controlled areas, these sUASs fall within Congress’s contemplated 

safety zone. HI Perspective will not operate its sUASs near airports as discussed above, 

and will not operate them in restricted airspace or over congested areas. HI Perspective

will operate its sUASs only on grounds with cordoned off areas or areas under control of 

the property owner or client. HI Perspective will determine the areas needed to fulfill the 

clients’ goals, and only operate its sUASs in these flight zones, and only in compliance 

with the restrictions imposed by the FAA. 

Finally, application of the same criteria demonstrates that there is no credible threat to 

national security posed by HI Perspective’s sUASs, due to their size, speed of operation, 

location of operation, lack of explosive materials or flammable liquid fuels, and inability 
to carry a substantial external load. Accordingly, HI Perspective’s sUASs will operate at 

and above current safety levels. 

In seeking this exemption, HI Perspective submits that its sUASs can operate safely in 

the NAS pursuant to FMRA Section 333, as demonstrated by: (a) the characteristics of HI

Perspective’s sUASs; (b) the pilot certification requirements; and (c) the specific 

operating limitations. 

(2) The Technical Specifications of HI Perspective’s sUASs Demonstrate its Safe 

Characteristics.

The proposed use of HI Perspective’s sUASs do not create a hazard to users of the NAS 

or the public, or otherwise pose a threat to national security, considering their size, 

weight, speed, and operational capability.

(a) Technical Specifications Of HI Perspective's sUASs: The technical 

specifications of HI Perspective's DJI Phantom 2 and DJI Inspire 1 have 

previously been submitted to the FAA with other exemption requests. 

(b) HI Perspective's sUASs Computer Assisted Flight And Navigation Modes 

Enable The sUASs To Remain Within A Defined Operational Area: HI 

Perspective's sUASs may be operated in both manual and computer assisted flight 

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

Perspective's DJI Phantom 2 and DJI Inspire 1 have previously been submitted to 

the FAA with other exemption requests. 

(3) (c) HI Perspective 's sUASs 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, HI Perspective 's UAs will remains stationary, in flight, for 3 

seconds or more. If, after 3 seconds, any of HI Perspective 's UAs does not 

reacquire control link data from the GCS, such UA will assume that the Control 

Link is lost, and the UA will return to the home position (i.e., failsafe mode) via 

GPS, and will descend to the takeoff position and shutdown. Flight Operations of 

HI Perspective's sUASs will be Limited to the Line of Sight of a Certificated Pilot 

in Command with a Visual Observer. 

To act as a pilot in command (PIC) of its sUASs, HI Perspective will only utilize pilots 

who possess a current and valid (1) Sports or Recreational Pilot Certificate, and (2) U.S. 

driver’s license. Additionally, for greater safety a visual observer (VO) will assist all 

pilots during flight time. 

(4) Flights of HI Perspective’s sUASs Will be Conducted Pursuant to Specific 

Operating Limitations. 
In seeking this exemption, HI Perspective proposes to operate commercially its sUASs 

for the special purpose of conducting aerial video and photography over certain areas of 

United States pursuant to the following specific operating limitations, and as specified in 

the FAA’s exemption authorization: 

(a) Operations will be limited to the following aircraft: rotorcraft sUASs weighing 

less than 6.7 pounds maximum gross weight i.e. DJI Phantom 2 and DJI Inspire 1. 

(b) Operations will be limited to operations conducted for the purpose of aerial 

video and photography for HI Perspective’s targeted clients, as described in 

Article II, above. 

(c) The sUASs will not be flown at an indicated airspeed exceeding 43 knots (22 

m/s) and will only operate in flight in phases or segments of equal to or less than 

20 minutes. In no case will HI Perspective’s sUASs be operated at airspeeds 

greater than the maximum UA operating airspeed recommended by the 

manufacturer for the applicable sUAS. 

(d) Operations will not be conducted in restricted airspace or over congested areas 

and will only be conducted as specified in the COA granted by the FAA. 

(e) HI Perspective’s sUASs will be operated at an altitude of no more than 400 

feet above ground level (AGL) and less than 2000 feet horizontally from a cloud 

or when visibility is less than 3 statute miles from the PIC. All altitudes reported 

to ATC will be in feet AGL. 

(f) HI Perspective’s sUASs will 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, if applicable, or U.S. driver’s license. 

(g) The use of first person view (FPV) by the PIC or the VO will not be permitted. 

(h) All operations will utilize a VO. 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 functions prescribed in 

the Operating Documents. 

(i) The VO will 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. 
(j) The Operating Documents, including the grant of exemption, will be accessible 

during HI Perspective’s sUASs operations, and will be 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 will be followed. Otherwise, the Operator will 

follow the procedures as outlined in its Operating Documents. The Operator 

and/or manufacturer 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 (AFS-80) will be contacted if questions arise regarding updates 

or revisions to the operating documents. 

(k) Prior to each flight the PIC will inspect the sUAS to be utilized to ensure that 

it is in a condition for safe flight. If the inspection reveals a condition that affects 

the safe operation of the sUAS, the aircraft will be prohibited from operating until 

the necessary maintenance has been performed and the sUAS is found to be in a 

condition for safe flight. The GCS must be included in the preflight inspection. 

All maintenance and alterations will be properly documented in the aircraft 

records. 

(l) If HI Perspective 's sUASs have undergone maintenance or alterations that 

affect their operation or flight characteristics, e.g. replacement of a flight critical 

component, such altered sUAS will undergo a functional test flight. The PIC who 

conducts the functional test flight must make an entry in the aircraft records. 

Functional flight test flights will 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 not to pose an undue hazard to persons and/or 

property. 

(m) The Operator will be responsible for maintaining and inspecting its sUASs to 

ensure each is in a condition for safe operation. 

(n) The pre-flight inspection will account for all potential discrepancies, e.g. 

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

sections of the Operating Documents. 

(o) The Operator will follow the sUASs’ manufacturer’s aircraft/component, 

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

(p) The Operator will 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 each of 

HI Perspective’s sUASs to service. 

(q) HI Perspective 's sUASs will comply with all manufacturer Safety Bulletins. 

(r) For each of HI Perspective’s sUASs, the authorized person will make an entry 

in the aircraft record of the corrective action taken against discrepancies 

discovered between inspections. 

(s) The PIC of each of HI Perspective’s sUASs will possess (i) at least a 

Recreational or Sport Pilot Certificate; (ii) at least a current third-class or higher 

medical certificate, or a valid U.S. driver's license, and (iii) at least 25 

documented hours operating the HI Perspective sUAS or one identical to it. 

 

(t) The Operator will not permit any PIC to operate unless the PIC meets the 

Operator’s qualification criteria, and demonstrates the ability to safely operate the 

applicable HI Perspective sUAS in a manner consistent with how such sUAS will 

be operated under the exemption, including evasive and emergency maneuvers 

and maintaining appropriate distances from persons, vessels, vehicles and 

structures. 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 

experience-building flights, all persons not essential for flight operations are 

considered nonparticipants, and the PIC must operate the applicable sUASs with 

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

or as otherwise required by the FAA. 

(u) HI Perspective's sUASs operations will not be conducted during night, as 

defined in 14 C.F.R. § 1.1. All operations must be conducted under visual 

meteorological conditions (VMC) during daytime and pursuant to VFR rules. 

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

(v) The UA will not operate within 5 nautical miles of an airport reference point 

as denoted on a current FAA Airport/Facility Directory (AFD), or, for airports not 

designated with an AFD, 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 as otherwise permitted by a COA issued to 

HI Perspective. The letter of agreement with the airport management must be 

made available to the Administrator or any law enforcement official upon request. 

(w) If any of HI Perspective 's sUASs loses communications or loses its GPS 

signal, it will return to a predetermined location within the planned operating area, 

and land or be recovered in accordance with the Operating Documents. 
(x) The PIC will abort the flight in the event of unpredicted obstacles or 

emergencies. 

(y) The PIC will be prohibited from beginning a flight unless (considering wind 

and forecast weather conditions) unless there is enough power to fly at normal 

cruising speed to the intended landing point and land the UA with 25% battery

power remaining. 

(z) All operations will be conducted in accordance with the Air Traffic 

Organization (ATO) issued Certificate of Waiver or Authorization (COA) issued 

pursuant to the grant of exemption. HI Perspective will apply for a new or 

amended COA if it intends to conduct operations that cannot be conducted under 

the terms of the COA issued pursuant to the exemption. 

(as) All aircraft operated in accordance with the exemption will 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 will be as large as practicable. The equivalent level of safety will be 

provided by having each of HI Perspective's sUASs marked on its fuselage as 

required by Section 45.29(f) where the pilot, observer and others working with the

sUAS will see the identification. 

(bb)The documents required to ensure the safe operation and flight of each sUAS 

and any document referred to by 14 C.F.R. §91.9 and §91.203 will be available to 

the PIC at the Ground Control Station of such sUAS any time the sUAS is 

operating. These documents will be made available to the Administrator or any 

law enforcement official upon request. 

(cc) HI Perspective's sUASs will remain clear and yield the right of way to all 

manned aviation operations and activities at all times. 

(dd) HI Perspective's sUASs will not be operated by the PIC from any moving 

device or vehicle. 

(ee) Flight operations will be in a confined area with a set safety perimeter, the 

boundaries of which are determined by HI Perspective personnel and coordinated 

with ATC, other FAA personnel, and local government officials, as applicable. 

(ff) Flight operations will 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: 

(i). Barriers or structures are present that sufficiently protect 

nonparticipating persons from the sUASs and/or debris in the event of an 

accident. The operator will ensure that nonparticipating persons remain 

under such protection. If a situation arises where a nonparticipating person 
leaves such protection and is within 500 feet of the sUAS, flight 

operations must cease immediately and/or; 

(ii). 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. 

The Operator, PIC, VO, operator trainees or essential persons will not be 

considered non-participatory persons. 

(gg) All operations will be conducted over private or controlled-access 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. 

(hh) All operations will be conducted with all required permissions and permits 

from any city, county or state jurisdiction, including local law enforcement, fire or 

other appropriate governmental agencies. 

(ii) Any incident, accident, or flight operation that transgresses the lateral or 

vertical boundaries of the operational area as defined by the applicable COA will 

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 website: www.ntsb.gov. 

(jj) HI Perspective will subscribe to relevant weather and safety alerts. 

(5) Reasons Why an Exemption from the Requirements of Section 61.113(a) and (b) 

Would Not Adversely Affect Safety. 

HI Perspective submits that the equivalent level of safety established by Section 

61.113(a) and (b) will be maintained as no PIC will be allowed to operate a sUAS unless 

that PIC has demonstrated that the PIC is able to safely operate the applicable HI 

Perspective sUAS in a manner consistent with the exemption, including evasive and 

emergency maneuvers and maintaining appropriate distances from people, vessels, 

vehicles and structures. 

(6) 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, as HI Perspective will ensure that each of its sUAS is in an 

airworthy condition based upon such sUAS’s compliance with its Operating Documents, 

and as stated in the conditions and limitations herein. 
(7) 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 each of HI Perspective’s sUASs will be provided to the PIC 

via GPS equipment and a radio communications telemetry data link, which downlinks 

from the applicable UA to the GCS for active monitoring of the flight path and altitude. 

This altitude information, combined with HI Perspective’s operation of its sUASs within 

visual line of sight, at or below 400 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 sUAS at ground level. 

(8) Reasons Why an Exemption from the Requirements of Section 91.151(a)(1) 

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(a)(1) as a result of (a) the technical specifications of HI 

Perspective’s sUASs; (b) the limitations on the proposed flight operations; and (c) the 

location of the proposed flight operations. Accordingly, HI Perspective will ensure that it 

will safely operate its sUASs during daylight hours in VFR conditions, with enough 

battery power to fly for a total duration of 15 minutes to the first point of intended 

landing and, assuming normal cruising speed, to fly after that for at least 5 minutes. 

Here, as in Exemption No. 11240, the technical specifications of HI Perspective 's

sUASs, 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(a)(1). Furthermore, safety will be ensured as HI Perspective 's sUASs will provide 

audible and visual warnings to the PIC at the GCS when such sUAS 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, HI Perspective 's sUASs 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 sUAS 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. 

(9) 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, HI Perspective 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 

HI Perspective will use trained technicians to perform maintenance, alterations, or 
preventive maintenance on its sUASs using the methods, techniques, and practices 

prescribed in the applicable Operating Documents. Furthermore, HI Perspective will 

document and maintain all maintenance records for its sUASs. 

Since HI Perspective’s sUASs will be inspected as prescribed by the applicable Operating 

Documents, HI Perspective will maintain the equivalent level of safety established by 

Sections 91.405(a), 91.409(a)(1), and 91.409(a)(2). 

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 HI

Perspective’s sUASs 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 applicable sUAS are 

considered. 

In consideration of HI Perspective’s proposed operating limitations, the Operating 

Documents, and the technical aspects of HI Perspective 's sUASs, HI Perspective’s 

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). 

(10) The FAA may prescribe any other conditions for safe operation.

In accordance with Section 333 of FMRA and 14 C.F.R. § 21.16 entitled Special 

Conditions, HI Perspective requests that the FAA prescribe special conditions for the 

intended operation of its sUASs, 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. §§ 61.23(a) & (c), 61.101 (e)(4) & (5), 

61.113(a) & (b), 61.315(a), 91.7 (a), 91.121, 91.151(a)(1), 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 HI Perspective’s sUASs 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 post 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 HI Perspective’s sUASs, if 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 sUAS. 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 HI Perspective’s intended operation of its sUASs, 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). 

(f) Summary that can be Published in the Federal Register

In accordance with 14 C.F.R. Part 11, the summary below is provided for publication in 

the Federal Register, should it be determined that publication is warranted: 

Applicant seeks an exemption from the following rules: 14 C.F.R. Part 21, subpart H; 14 

C.F.R. § 45.23; 14 C.F.R. § 45.27(a); 14 C.F.R. § 61.23(a) & (c),§ 61.101 (e)(4), § 

61.113(a) & (b); 14 C.F.R. § 61.315; 14 C.F.R. § 91.7(a); 14 C.F.R. § 91.9(b)(2); 14 

C.F.R. § 91.103; 14 C.F.R. § 91.119; 14 C.F.R. § 91.121; 14 C.F.R. § 91.151(a); 14 

C.F.R. § 91.405(a); 14 C.F.R. § 91.407(a)(1); 14 C.F.R. § 91.407(a)(1); 14 C.F.R. § 

91.409(a)(2); and 14 C.F.R. § 91.417(a) & (b) to operate commercially a small unmanned 

vehicle in aerial photography and videography over certain areas of the United States. 

However, HI Perspective submits that good cause exists for not publishing a summary of 

the petition in the Federal Register as the exemptions requested by HI Perspective would 

not set a precedent, and any delay in acting on the petition would be detrimental to the 

petitioner. 

(g) Any Additional Information, Views, Or Arguments Available to Support HI 

Perspective’s Request

This Petition is made pursuant to the FMRA Section 333, which directs the Secretary of 

Transportation to determine if certain UAS may operate safely in the NAS. As such, HI

Perspective’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, HI Perspective will operate its sUASs safely in the NAS, without creating a 

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

(h) Request for Summary Grant
HI Perspective requests that the FAA issue a summary grant with respect to the 

exemptions requested for HI Perspective’s sUASs as grants have been given previously 

to other operators who are operating the same sUASs, e.g. Exemptions Nos. 11062, 

11109, 11112, 11213, 11641, 11639, 11240, 11654,11656, 11658, 11659, 11660, 11663, 

11664, 11655, 11669, 11670, 11672, 11639, 11641, 11642, 11644, 11626.