August 19, 2015

U.S. Department of Transportation Docket

Management System

1200 New Jersey Ave., SE

Washington, DC 20590

SUBJECT: Exemption Request under Section 333 of the FAA Reform Act and Part 11 of the 

Federal Aviation Regulations.

Dear Sir or Madam:

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 and 14 C.F.R. Part 11, TFF 

Production, Inc. (TFF), the owner and operator of the DJI Inspire 12a small Unmanned Aircraft System 

(sUAS) seeks an exemption from Federal Aviation Regulations (FARs) identified below, to allow 

commercial operations of small unmanned aircraft (i.e., “small unmanned aircraft” or “UA”) because we 

desire to assist in the safe and legal integrations of UA’s into the NAS. 

We believe that TFF is eligible for a Summary Grant for the proposed closed set filming, data 

collection1, and demonstrations. We have carefully reviewed approved exemptions granted under 

section 333 by the FAA and believe our request for an exemption to be materially similar to exemptions 

below and in the public’s best interest. 

Operation Exemption Numbers:

11062 to Astraeus Aerial (see Docket No. FAA−2014−0352) 

11109 to Clayco, Inc. (see Docket No. FAA−2014−0507) 

11112 to VDOS Global, LLC (see Docket No. FAA−2014−0382) 

11213 to Aeryon Labs, Inc. (see Docket No. FAA−2014−0642)

11241A to Phoenix Air Unmanned, LLC (see Docket No. FAA−2014−0692)

11970 to Camera Copters, Inc. (see Docket No. FAA-2015-1100)

DJI Inspire 1 (UA) Exemption Numbers:

11279 to CineDrones, LLC (see Docket No. FAA-2014-0798)

11280 to Shotwell Media, LLC (see Docket No. FAA-2014-0885)

11288 to Toledo Aerial Media, LLC (see Docket No. FAA-2014-0979)

11303 to TradeCraft, LLC (see Docket No. FAA-2014-1019)

11313 to DeGrazia Music, LLC (see Docket No. FAA-2014-1085)

11314 to Ryan K. Koffman (see Docket No. FAA-2014-0958)

The proposed Summary Grant exemption, if granted, would permit TFF, which uses the DJI Inspire 12, 

to conduct closed set film/television production, aerial data collection1, and flight demonstrations. TFF’s 
Page 2

operation under the exemption will be subject to strict operating requirements and conditions to ensure a 

greater level of safety to currently authorized operations using manned and unmanned aircraft under 

conditions as may be modified by the FAA as required by Section 333.

_______________________

1Aerial data collection includes any remote sensing and measuring by an instrument(s) aboard the UA. 

Examples include imagery (photography, video, infrared, etc.), electronic measurement (precision 

surveying, RF analysis, etc.), chemical measurement (particulate measurement, etc.), or any other 

gathering of data by instruments aboard the UA.

2

The FAA has previously authorized use of the DJI Inspire for commercial purposes on multiple 

occasions (e.g., Exemption Nos.11447, 11458, 11461, and 11463).

For ease of review, TFF has organized the Exemption request using a table of contents that can be 

found on page 3.
Page 3

TABLE OF CONTENTS

I. UAS....................................................................................................................4

II. Petitioner's Description........................................................................................................5

III. Petitioner’s Contact Information.................................................................................5

IV. Proposed Operations.............................................................................................5-7

V. Crew Qualifications and Duties.................................................................................7-8

VI. Public/Community Interest........................................................................................8

VII. FCC Information..................................................................................................9

VIII. Regulations From Which Exemption is Requested.................................................................9-13

IX. Privacy..............................................................................................................14

X. Conclusion................................................................................................................14-15

SUPPORTING MATERIAL

APPENDIX A

Inspire 1 Maintenance Manual...................................................................................16-18

Inspire 1 Safety Guidelines ......................................................................................19-23

Inspire Intelligent Flight Battery Safety Guidelines..........................................................24-26

SUBMITTED CONFIDENTIALLY TO 333exemption@faa.gov

Petitioner submits its Manuals, as a Confidential documents under 14 CFR § 11.35(b), as the Manuals 

contain confidential commercial and proprietary information that the Petitioner has not and will not 

share with others. The Manuals contain operating conditions and procedures that are not available to the 

public and are protected from release under the Freedom of information Act.

1. Inspire 1 Quick Start Guide

2. Inspire 1 User Manual

3. TFF Motion Picture & Television Operations Manual (MPTOM)

4. TFF Flight Operations Procedures Manual (FOPM)
Page 4

I. UAS

Tyler Furlan, TFF Production, Inc. (TFF) is petitioning for and exemption to operate a DJI Inspire 1 

quadcopter. This quadcopter has an advanced flight controller that constantly updates and records using 

a high-strength, intelligent GLONASS + GPS System. This dual position system allows for greater 

safety and higher precision. In addition the Inspire 1 has advanced Inertial Measurement Unit (IMU) 

that has a 6-axis gyroscope and accelerometer to monitor any change in the sUAS’s attitude and 

movement. These systems allow the Inspire 1 to operate safely and compensate and adjust 

immediately to hold its precise position at all times. In addition the DJI Inspire 1 can accommodate 

two operators a Pilot in Command (PIC) and a payload operator. This also enhances safety by 

allowing the PIC to operate the sUAS and concentrate only on flying the sUAS while the payload 

operator controls the camera. The sUAS will be equipped with cameras, camera stabilizing gimbals 

and on‐screen displays (OSD) providing the PIC with altitude, airspeed, battery life and direction. The 

GLONASS + GPS system will be used to limit the altitude above the ground and limit the distance it 

flies from the PIC. The Inspire 1 has GPS guided failsafe functions that command the autopilot to fly 

the sUAS back to the original launch site autonomously. This failsafe will be triggered if the system 

loses the minimum number of GLONASS + GPS signals or if the signal from the transmitter is lost or 

if the PIC decides to abort the flight.

UA: DJI Inspire 1

Manufacturer: DJI Innovation

Model: Inspire 1 T600 

Weight: 2935 g / 6.47 Pounds 

Passenger Capacity: 0 (unmanned) 

Size (dimensions): 438x451x301 mm (17.24x17.76x11.85 inches) 

Max Speed: 22 mps (72.18 fps / 49.21 mph) 

Max Flight Time: 18-25 mins 

Max Ceiling (software limited): 400 ft. AGL 

Operations: Line of Sight 

Controller: The Inspire’s omni-directional antenna has a range of 2 km

Radio Frequency: Operates in the 2.420 – 2.483 GHz frequency from Controller to Aircraft

 Operates in the 5.725 – 5.850 GHz frequency from Controller to Controller
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II. Petitioners Description

Tyler Furlan, TFF Production, Inc. (FTT) is petitioning for an exemption and is a company that 

provides unmanned aerial support to closed set film/television production, aerial data collection1, and

demonstrations. 

TFF has over 200 hours of flight training and experience with the DJI Inspire 1 and several PIC 

candidates who hold at a minimum a Recreational Pilots License. TFF has over 10 years of video 

production and closed set film/television experience and understands the requirements to safely 

integrate UA on movie sets to increase the safety of all participants. 

TFF plans on providing a wide range of services as the UAs market expands. 

III. Petitioner’s Contact Information:

TFF Production, Inc.

Attn: Tyler Furlan

4329 N Drake Ave.

Chicago, IL 60618

Phone: (302) 918-5010

Email: 333petition@gmail.com

IV. Proposed Operations

 Before an operation of a sUAS within 5NM of an airport with a control tower, the control tower 

will be called to gain permission to operate the sUAS. The PIC will give the position, altitude, 

and the times the sUAS will be operated. The sUAS will not be operated at an altitude of over 

150 ft. AGL unless otherwise cleared.

 Before an operation of a sUAS within 5NM of a non‐tower controlled airport, airport operators 

will be notified and the PIC will give the right of way to avoid flying in the proximity of 

full‐scale aircraft. At no time will the sUAS be operated within the final approach course and the 

takeoff course of any runway. The sUAS will not be operated at an altitude of over 200 ft. AGL

unless otherwise approved by the air operators. 

 Weather minimums will be 3 miles visibility and a 1000 ft. ceiling. 

 TFF will only operate its sUAS in line of sight of a PIC and/or VO and will operate at sites that 

are a ‘sufficient distance’ from populated areas. Such operations will insure that the sUAS will 

not create a hazard to users of the NAS or the public.
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 All flight operations will be conducted at least 500 feet from all non-participating person, 

vessels, vehicles, and structures unless

(a) Barriers or structures are present that sufficiently protect nonparticipating persons from 

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

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

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

operations must cease immediately in a manner ensuring the safety of nonparticipating 

persons. 

(b) The owner/controller of any vessels, vehicles or structures has granted permission for 

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

operating closer to those objects and determined that it does not present an undue hazard. 

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

persons under this exemption

 All of our operations will be less than 200 ft. AGL if we are operating within 30 miles reach of

primary class B airports with in the United States.

 Maximum flight time for each operational flight will be less than 30 minutes. 

 Flights will be terminated at 25% battery power reserve should that occur prior to the 20 minute 

limit. 

 The sUAS will utilize ‘GPS fences’ so that it will not be operated at an altitude of no more than 

400 ft. AGL, and not more than 200 ft. above an elevated platform from which data collection is 

planned. 

 Minimum crew for each operation will consist of the PIC and VO. 

 The sUAS operated by the petitioner weighs less than 55 lbs., including the payload. 

 The sUAS will operate at speeds of no more than 40 knots, can hover, and can simultaneously 

move vertically and horizontally. 

 All operations must utilize a VO. The VO and the PIC must be able to communicate by voice, 2 

way radio, or cellular communications at all times during flight operations. 

 Flight operations will be restricted to flights over water, public or private property with the 

permission of the property owner(s). 

 All required permits will be obtained from state and local government prior to operation. 

 sUAS will not be operated over densely populated areas unless proper authorization and barriers 

are set in place. 
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 sUAS will not be operating over any open‐air assembly of people. 

 sUAS will not be operating over heavily trafficked roads. 

 All new to service sUAS both custom and pre‐manufactured will have a minimum of 25 logged 

flight hours and deemed safe by the PIC prior to commercial operations. 

 Flight operations will also adhere to the specifications stated in the DJI Safety Guidelines 

(downloadable at this link: http://www.dji.com/product/inspire-1/download)

 The sUAS will be maintained in accordance with the maintenance specified in the User Manual 

and the Maintenance Manual (downloadable at this link http://www.dji.com/product/inspire1/download)

V. Crew Qualifications and Duties

The PIC will maintain at least a Sport Pilot License and a current Class III medical certificate, plus at 

least 10 hrs. Of flight time on the DJI Inspire 1 and at least 2 hrs. of flight time with 3 takeoffs and 

landings within 30 days of sUAS operations. The PIC will have at least 100 hrs. Total flight time and at 

least 20 hrs. Flying RC aircraft of that 10 hrs. On the DJI Inspire 1. 

The PIC is responsible for the safe and efficient operation of the aircraft. Specific duties include all 

preflight preparation, in flight operation, and post flight requirements. Procedures including but not 

limited to. 

PIC Duties:

 Utilize the FAA B4UFLY App to verify legal and safe operation in the planned flight area

 Risk Assessment

 Pre-Flight Site Inspection 

 Pre‐Flight Check List

 Ensure Safe Flight Operations

 Safety Briefing

The Visual Observer (VO) must have the visual acuity to observe the sUAS and be able to communicate 

clearly with the PIC verbally, 2 way radios, or by cellular communications at all times. The VO is not 

allowed to use any visual assist ques other than corrective lenses as prescribe on their valid state driver’s

license or third class medical certificate. Duties for the VO are as follows but not limited to. 

VO Duties: 

 Creating a pre‐flight weather report utilizing a personal weather station to collect data on the wind 

 speed, ambient temperature, and barometric pressure. 

 Notifying the PIC of any impending obstacles in the flight path of the sUAS

 Notifying the PIC of any deviations in the planned flight path of the sUAS

 Notifying the PIC if unauthorized persons enter the area of the planned flight
Page 8

The DJI Inspire one has a second controller which allows the operator of the UA to completely focus on 

flight operations. The camera operator (CO) will be in close proximity to the UA operator and be able to 

communicate through 2 way radios, verbally, or with cellular communications at all times. The camera 

operator’s duties are as follows but not limited to. 

Camera Operator (CO) Duties:

 Pre-Flight Camera Inspection

 Pre-Flight Shot List Assessment

 Pre-Flight Check List

VI. Public Interest

TFF’s qualified PIC’s and competent pilots will be operating according to limitations necessary to 

ensure the safety of people, vessels, vehicles, or structures. Production personnel are exposed to 

manned aircraft which is a high risk to their safety due to manned aircraft weight, size, speed, and 

payload capacity. (See Appendix A) 

The UA is also able to respond to a lost-link event with a pre-coordinated, predictable, automated flight 

maneuver. These safety features have no adverse effect to participating and nonparticipating individuals 

compared to a manned aircraft that holds a standard airworthiness certificate performing a similar 

operation and ensure that these operations will not adversely impact the safety of the public and thus 

being in the public’s best interest. 

The sUAS operated by TFF are powered by batteries, are small, quieter, lighter, and more maneuverable 

than larger aircraft running on combustible fuel, thus leaving a very small environmental impact. Our 

sUAS operate at lower altitudes and have no people on board, thereby reducing the risk levels associated 

with traditional aircraft and larger UAS. These factors increase the safety of operation and reduce the 

risk of death or serious bodily injury by our aircraft. Also, with a limited payload and short flight 

duration, there is little risk to national security.

Low altitude data collection methods are more efficient than ground based observations or manned 

aircraft imagery for displaying detailed characteristics of ground based objects. Because of the above 

mentioned characteristics of our sUAS, TFF intends to sell their data at a significantly reduced cost 

allowing for more clients to be able to afford this type of data. The benefits of unmanned sUAS data 

collection methods and continued development and improvement of small sensors and increased flight 

times will benefit future clients greatly. 

TFF continues to witness UA operations take place illegally because of the growing demand. We 

believe that it’s in the public’s best interest and our own to receive an exemption allowing us to work 

towards building a community of legal and responsible operators in the Midwest. 
Page 9

VII. FCC Information

The transmitter used for controlling the UA complies with part 15 of the FCC rules. Operation is subject 

to the following two conditions:

(1) This device may not cause harmful interference 

(2) This device must accept any interference received, including interference that may cause undesired 

operation.

The Spektrum radio transmitter used for controlling the UA is wireless technology which has been 

tested and found to be compliant with the applicable regulations governing a radio transmitter in the 

2.400GHz to 2.4835GHz frequency range.

Antenna Separation Distance

When operating our transmitter, the PIC will maintain a separation distance of at least

5 cm between his body (excluding fingers, hands, wrists, ankles and feet) and the antenna to meet RF 

exposure safety requirements as determined by FCC regulations.

VIII. Regulations from which exemption is requested

 14 C.F.R. 11.87 Publication and Comment Procedure

 14 C.F.R. Part 21 Airworthiness Certification

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

 14 C.F.R. 61.113(a) and (b) Private Pilot Privileges and Limitations

 14 C.F.R. 91.109 Flight Instructions

 14 C.F.R. 91.119 Minimum Safe Altitudes

 14 C.F.R. 91.121 Altimeter Settings

 14 C.F.R. 91.151(a) Fuel Requirements for Flights in VFR Conditions

 14 C.F.R. 91.203 (a) & (b) Civil Aircraft: Certifications Required

 14 C.F.R. 91.215 ATC Transponder and Altitude Reporting Equipment Use

 14 C.F.R. (91.401 - 91.417) Maintenance, Preventive Maintenance, Alterations
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14 C.F.R. 11.87: Publication and Comment Procedure

TFF requests that the publication and comment procedure be waived to help move towards a Summary

Grant in accordance with 14 C.F.R 11.87 which states the “...circumstances in which FAA may decide 

not to publish a summary of my petition for exemption?” 

a) TFF does not set any precedent and agrees to the SAME limitations on operations and on their 

DJI Inspires as exemptions 11279, 11280, and 11288.

b) In pursuit of a Summary Grant we believe the publication and comment procedures would 

delay the process. 

c) We also feel it would affect our ability to serve in the public’s best interest because there are 

several operations currently being done illegally as many clients are looking for companies with 

exemptions. However, since there are so few companies in Chicago they are choosing to hire 

companies who are operating illegally. If we are able to obtain a summary exemption we believe 

it would be in the public safety, the FAA, potential clients, and our own best interest. 

d) We also feel that we’ve filed our information in a timely manner and could help free up limited 

resources to focus on other more complicated tasks.

14 C.F.R. Part 21, Airworthiness Certificates

This part establishes the procedures for the issuance of an airworthiness certificate. While the FAA 

continues to work to develop airworthiness standards for Unmanned Aerial Systems, I request an 

experimental certificate be issued for the DJI Inspire 1 under either or both of the following provisions: 

21.191 Experimental certificates. Experimental certificates are issued for the following purposes: 

(a) Research and development Testing new aircraft design concepts, new aircraft equipment, new 

 aircraft installations, new aircraft operating techniques, or new uses for aircraft.

(b) Showing compliance with regulations. Conducting flight tests and other operations to show 

compliance with the airworthiness regulations including flights to show compliance for issuance 

of type and supplemental type certificates, flights to substantiate major design changes, and 

flights to show compliance with the function and reliability requirements of the regulations. 

Since the experimental certificate can be used for commercial purposes such as market surveys, 

sales demonstrations, and customer crew training, I would expect that an experimental certificate 

would permit my commercial purpose as well. The aircraft will not carry persons or property, 

will not carry fuel, and will only fly under strict operational requirements. Combined with the 

UA's light weight, being constructed primarily of carbon fiber and plastic, I propose that the UA 

will be at least as safe, if not safer, than a conventionally certificated aircraft performing the 

same mission. If an experimental airworthiness certificate is not appropriate for this application, 

then I request an exemption of 14 CFR Part 21, Subpart H, and the requirement for airworthiness 

certificate in general, citing the equivalent level of safety outlined in the previous paragraph.
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14 CFR 45.23 Marking of the Aircraft

Applicable Codes of Federal Regulation require aircraft to be marked according to certain specifications. 

My UAS are, by definition, unmanned. They therefore do not have a cabin, cockpit or pilot station on 

which to mark certain words or phrases. Further, two-inch lettering is difficult to place on such small 

aircraft with dimensions smaller that minimal lettering requirement. 

Each TFF UA will carry its appropriate “N” number issued by the FAA, in such size as can reasonably 

fit upon the sides of the aircraft in at least one location. If an N number is not obtained from the FAA, I 

will mark TFFs related Training UAS in the largest possible lettering by placing the word 

“EXPERIMENTAL” on its airframe as required by 14 C.F.R. §45.29 (f) so that I the pilot, or anyone 

assisting me as a spotter with the UA will see the markings. The FAA has previously issued exemptions 

to this regulation through Exemptions Nos. 8738, 10167, 10167A and 10700.

Finally, we will display at the ground station a high contrast flag or banner that contains the words 

"Unmanned Aircraft Ground Station" in letters 3 inches high or greater. Since the aircraft will operate 

within .5 miles of the ground station, the banner should be visible to anyone that observes the aircraft 

and chooses to investigate its point of origin.

14 C.F.R. § 61.113: Private Pilot Privileges and Limitations

Pursuant to 14 C.F.R. §§ 61.113 (a) & (b), private pilots are limited to noncommercial operations. The 

FAA has previously ruled in its exemption that a Private Pilot’s Certificate is required for flight of the 

UAS for commercial purposes. TFF proposes that the Pilot in Command will carry a minimum of a 

Recreational Pilots Certificate with a third class medical or valid state driver’s license. TFF will assure 

that all PIC’s proposed to oversee the operations of the UAS aircraft also have at minimum of 25 hours 

flight time on the UAS being used for the operation. 

TFF’s UAS’s do not carry any pilots or passengers. The risks attended to the operation of my UAS is far 

less than the risk levels inherent in the commercial activities outlined in 14 C.F.R. § 61, et seq. Thus, 

allowing any TFF qualified operator or PIC with a minimum of a Recreational Pilot License to oversee 

operations of the proposed UAS’s to meet and exceed current safety levels in relation to 14 C.F.R. 

§61.113 (a) & (b).

14 C.F.R. 91.109 Flight Instructions

The regulation states that "No person may operate a civil aircraft that is being used for flight Instruction 

unless that aircraft has fully functioning dual controls." Training will be conducted by TFF. We have 

the ability to provide dual controls utilizing two C1 transmitters with a wired link between the 

transmitters. One transmitter is designated the master transmitter and the other transmitter is designated 

as a slave. Please refer to the attached DJI Inspire 1 User Manual. The PIC instructor, utilizing the 

master transmitter, will be at all times be able assume control of the sUAS
Page 12

14 C.F.R. 91.119: Minimum Safe Altitudes

14 C.F.R. § 91.119 prescribes safe altitudes for the operation of civil aircraft. It allows helicopters to be 

operated at lower altitudes in certain conditions. TFF UAS will never operate at an altitude greater than 

400 AGL. 

The regulation states that over sparsely populated areas the aircraft cannot be operated closer than 500 

feet to any person, vessel, vehicle, or structure. Since the typical mission of the sUAS would be closed 

set motion picture filming, aerial data collections, and demonstrations of persons, vessels, vehicles, or 

structures it would be necessary to operate closer than 500 feet to the items listed. Operations will only 

be flown over property or person(s) where permission has been obtained and careful pre-planning has 

been performed. The aircraft will be operated at a low altitude allowing, if a power unit fails, an 

emergency landing without undue hazard to persons or property on the surface. Therefore we maintain 

that due to the small size of the UAS, the hazard to persons, vehicles and structures is minimal compared 

to manned aircraft, which should be considered in granting the exemption.

14 CFR 91.121 Altimeter Settings

The regulation requires that aircraft shall maintain cruising altitudes by reference to an altimeter setting 

available within 100 NM of the aircraft. The sUAS will always fly below 600 feet AGL and will not 

need to maintain cruising altitudes in order to prevent conflict with other aircraft. An Above Ground 

Level altimeter measurement above the takeoff point is transmitted via radio from the sUAS on-board 

computer to the display screen held by the PIC, providing a constantly updated AGL readout.

14 CFR 91.151 Fuel Requirements for Flight in VFR Conditions

The regulation provides that no person may begin a flight in an airplane under day-VFR conditions 

unless there is enough fuel to fly to the first point of intended landing and to fly after that for at least 30 

minutes. We feel the intention of this paragraph is to provide an energy reserve as a safety buffer for 

delays to landing. The sUAS are battery operated and the maximum duration of flight from a single 

battery charge is 12-45 (depending on which sUAS) minutes with a 20% reserve. Since the aircraft will 

never fly more than 1/2 NM from the point of intended landing, a full battery charge at launch will 

ensure that we meet the reserve energy requirement of this paragraph. We request an exemption to the 

word "fuel" and ask for an equivalent interpretation with the word "energy". We also request exemption 

from the 30 min reserve and ask that our reserve will be to fly the mission to the point of intended 

landing and have at least a 20% battery reserve after that.

14 CFR 91.203(a) & (b) Civil Aircraft: Certifications Required

The regulation provides that an airworthiness certificate, with the registration number assigned to the 

aircraft and a registration certificate must be aboard the aircraft. Additionally, subparagraph (b) provides 

that the airworthiness certificate be "displayed at the cabin or cockpit entrance so that it is legible to 

passengers or crew. TFF’s largest UA, the DJI Inspire 1, at a maximum gross weight of 7 pounds, the 
Page 13

sUAS is too small to carry documentation, does not have an entrance, and is not capable of carrying 

passengers or crew. To obtain an equivalent level of safety and meet the intent of 91.203, we propose 

that documents deemed appropriate for this aircraft by the FAA will be located with the crew at the 

ground control station and available for inspection upon request

14 C.F.R. 91.215 ATC Transponder and Altitude Reporting Equipment and Use 

This regulation states all aircraft operating within 30 Nautical Miles of class A, B and C airspace must 

be equipped with automatic pressure altitude reporting equipment having a Mode C capability that 

automatically replies to Mode C interrogations. Due to the small size and lifting capabilities of our 

UASs we cannot carry a traditional transponder. All of our operations will be less than 250 ft. AGL if 

we are operating within the 30NM reach of a mode c vail.

14 CFR Subpart E (91.401- 91.417) - Maintenance, Preventive Maintenance, Alterations

The regulation provides that the operator is primarily responsible for maintaining the aircraft in an 

airworthy condition, including compliance with part 39 and 43. Paragraphs 91.407 and 91.409 require 

that the aircraft be "approved for return to service by a person authorized under 43.7" after maintenance 

and inspection. It is our intention that the PIC perform maintenance and inspection of the aircraft and 

"be authorized to approve the aircraft for return to service." The PIC will ensure that the aircraft is in an 

airworthy condition prior to every flight. 

The UAS Inspection program will be every 50 hr. or 200 flights as suggested at the top of the attached 

Inspire 1 Maintenance Manual (Appendix A). Other required tests and inspections (transponder, E.L.T., 

etc.) will be performed as per Part 91 when necessary. Each aircraft will have a flight log containing 

upcoming scheduled maintenance and inspections and the dates or times they must be performed. A 

section for discrepancies is also found in the flight log. The pilot in command will assure the aircraft to 

be flown is in airworthy condition and all required inspections and maintenance has been completed 

before each flight

The DJI Inspire 1 is nearly maintenance free, it performs automatic preflight checks and the failure of 

any check will prevent take-off. Checks which cannot be done by the system will be performed by a 

qualified person prior to each flight and at predefined intervals as part of the Maintenance Schedule in 

the User Manual (see Exhibit 1). 

Preflight checklist includes: 

1. Visual inspection of the airframe 

2. Visual inspections of rotor integrity 

3. Check charge of all batteries (aerial vehicle, command station, radio repeater station) 

An equivalent level of safety will be achieved because the sUAS is small in size, will carry no external 

payload, will operate only in restricted predetermined areas and is not a complex mechanical devise. As 

provided in the attached User Guide (System Maintenance section), the operator of TFF will ensure that 
Page 14

the sUAS is in working order prior to initiating flight, perform required maintenance, and keep a log of 

any maintenance that is performed. Moreover, the operator is the person most familiar with the aircraft 

and is best suited to maintain the aircraft in an airworthy condition and to ensure an equivalent level of 

safety.

Maintenance performed by the PIC is limited to repairing small cracks, replacing a propeller, checking 

electrical connections and updating software and firmware for the on-board computer. All other

maintenance will be performed by the manufacturer or their designated repair facility. The PIC will 

document work performed in accordance with 91.417. We feel that due to the size, construction, and 

simplicity of the aircraft, the PIC can ensure an equivalent level of safety.

IX. Privacy

There is little risk that the proposed use of the DJI Inspire 1 by TFF will result in any privacy violations 

because all flights will occur over private or controlled access property with the property owner’s prior 

consent and knowledge. When a UA is being flown, the onboard cameras will be focused on the ground 

beneath it, and thus turned so as to be facing away from any occupied structures that may be in the area 

to minimize inadvertent video or still images of uninvolved persons. TFF will also make sure to be 

aware of concealing itself from heavily trafficked nearby roads by using the landscape to avoid causing 

driver distractions. 

All data collected that is used for public view, all images containing uninvolved person whom have not 

signed a release will be blurred or blacked-out. No attempt will be made to identify any individuals 

filmed during the flights except in cases where they are trespassing upon or damaging customer property, 

or interfering with the petitioner’s or it’s customer’s operations. 

X. Conclusion

By granting Tyler Furlan, owner, TFF Productions, Inc. the requested summary grant exemptions, the 

FAA will help ensure the development of safe and successful commercial UAS operations and will 

advance the public knowledge and perception for such operations of sUAS. TFF personnel have a long 

history with Remote Controlled. We are committed to promoting the sUAS research efforts of 

policymakers by sharing data from our commercial sUAS operations and serving as a resource for future 

sUAS research opportunities. 

TFF sUAS used, under authorization by the US DOT‐FAA, are small, light‐weight (under 55 lbs.) 

devices that will be operated only in daylight within the line of sight of the PIC and VO, they will 

operate under 400 ft. AGL and outside 5NM from any airport or location with aviation activities, unless 

the air traffic control (ATC) authorities have been properly notified and that the ATC authorities have 

authorized each flight within the specified radius of their facilities. 

TFF seeks an exemption pursuant to 14 C.F.R. and Section 333 of the FAA Modernization and Reform 

Act of 2012 (FMRA), which will permit the safe operation of our sUAS commercially, without an 

Airworthiness Certificate. By granting this Petition, the FAA Administrator will be fulfilling the 

Congressional mandate of the FMRA of 2012, while also advancing the interests of the public, by 
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allowing TFF to safely, efficiently, and economically operate our sUAS commercially within the 

NAS. In accordance with the FAA Regulations and the FMRA of 2012, Section 333, TFF respectfully 

requests that the Administrator grant this petition for a summary grant exemption from the 

requirements of 14 C.F.R Sections.

If additional information is required, or if you have any questions regarding this petition for a 

summary grant Exemption, please don’t hesitate to contact me at (302) 918-5010 or 

333petition@gmail.com

 Kind Regards,

 Tyler Furlan
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APPENDIX A: 
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