UNITED STATES OF AMERICA 

DEPARTMENT OF TRANSPORTATION 

FEDERAL AVIATION ADMINISTRATION 

WASHINGTON, DC 

IN THE MATTER OF THE PETITION FOR EXEMPTION OF: 

Flycam, LLC 

FOR AN EXEMPTION SEEKING RELIEF FROM THE REQUIREMENTS OF 

TITLE 14 OF THE CODE OF FEDERAL REGUI.ATIONS 

SECTIONS 61.113(a) &(b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & 

(a)(2), AND 91.417(a) &(b) CONCERNING COMMERCIAL OPERATION OF DJI INSPIRE 1 

UNMANNED AIRCRAFT SYSTEMS 

PURSUANT TO SECTION 333 OF 

THE FAA MODERNIZATION AND REFORM ACT OF 2012 

(PUBLIC LAW 112-95) 

Submitted on June 20, 2015 

Flycam, LLC 

Attn: Roland Lyons & Andy Anderson 

804 N. 1551h Ave 

Omaha, Ne 68154 

402-913-6331 
TABLE OF CONTENTS 

GLOSSARY OF ABBREVIATIONS ......................................................................................................... 3 

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

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

BACKGROUND.................................................................................................................................... 4 

BASISFOR PETITION ........................................................................................................................... 4 

A. Name And Address Of The Petitioner . ..................................................................................... 6 

B. The Specific Sections Of 14 C.F.R. From Which Flycam, LLC Seeks Exemption . .................... 6 

C. The Extent Of Relief Flycam, LLC Seeks And The Reason Flycam, LLC Seeks The Relief. ...... 8 

D. The Reasons Why Granting Flycam, LLC Request Would Be In The Public Interest ............ 10 

E. The Reasons Why Granting The Exemption Would Not Adversely Affect Safety ............... 12 

F. The Rules From Which Flycam, LLC Seeks Exemption ......................................................... 21 

G. Any Additional lnformation, Views, Or Arguments Available To Support Request. .......... 22 

CONCLUSION.................................................................................................................................... 22 

APPENDICES..................................................................................................................................... 23 

APPENDIX — A: DJl lnspire 1 Technica) Specifications ................................................................ 24 

APPENDIX — B: DJi Inspire 1 Manufacturer's User Manua) ........................................................ 25 

APPENDIX — C: DJI Inspire 1 Manufacturer's Maintenance Manual .......................................... 26 

APPENDIX — D: DJI Inspire 1 Manufacturer's Safety Guidelines ................................................ 27 

2 
GLOSSARY Of ABBREVIATIONS 

AGL Above Ground Level 

AOI Area of Interest 

ATC Air Traffic Control 

ATO Air Traffic Organization 

AV Aeria) Vehicle 

CFR Code of Federal Regulations 

COA Certificate of Authorization 

FAA Federal Aviation Administration 

FAR Federal Aviation Regulation 

GCS Ground Control Station 

GPS Global Positioning System 

LOL Loss of Link 

NAS National Airspace System 

NOTAM Notice to Airman 

PIC Pilot In Command 

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

SO Safety Observer 

SOP Standard Operating Procedures 

UA Unmanned Aircraft 

UAS Unmanned Aircraft System 

VFR Visual Flight Rules 

VLOS Visual Line of Site 

VMC Visua( Meteorological Conditions 

VTOL Vertical Takeoff and Landing 

3 
SUMMARY 

Fiycam, LLC seeks exemption from the requirements of 14 C.F.R §§ 61.113(a) &(b), 913(a), 91.121, 91.151(b), 

91.405(a), 91.407(a)(1), 91.409(a)(1) &(a)(2), and 91.417(a) &(b), to operate an Unmanned Aircraft System pursuant to 

Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA). This exemption will permit Flycam, LLC to 

operate an Unmanned Aircraft System (UAS) for the commercial purpose of conducting aerial video and photography of 

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

1NTRODUCTION AI11D INTERESTS OF THE PETITIONER 

Flycam, LLC, hereto referred in this document as Flycam , provides its clients with over 20 years of expertise and 

knowledge of Professional video and photography operations. Flycam's mission is to provide high quality imaging for a 

variety of commercial, public, and residential uses, specifically targeting: 

• Aerial acquisitions used for inspections of private structures 

• Private event photography and videography 

• Construction sites before and after 

• Real-estate marketing 

• Motion Picture and Commerciai Filming 

BACKGROUND 

Unmanned Aircraft Svstems: DJI Inspire 1 UAS 

Flycam seeks an exemption to operate DJI systems for compensation or hire within the NAS. The DJI 

Inspire 1 vertical takeoff and landing (VTOL) Unmanned Aircraft (UA) with a Ground Control Station 

(GCS) utilizes electronic tablet or smart phone systems. The DJI Inspire 1 has a maximum gross weight of 

6 pounds 7.5 ounces, a length of 17.3 inches, width of 17.7 inches, height of 11.8 inches, and a maximum speed of 

approximately 42 knots. The DJI Inspire 1 UA is equipped with four main rotors; driven by Lithium Polymer battery 

powered electric motors. 

The DJI Inspire 1 UA that wil) be operated by Flycam will be registered in accordance with 49 U.S.C. 44103, Registration 

of Aircraft, as well as 14 C.F.R Part 47, Aircraft Registration, and marked in accordance with 14 C.F.R. Part 45, 

Identification and Registration Marking. 

BASIS FOR PETITION 

Petitioner, Flycam, pursuant to the provisions of the Federal Aviation Regulations (14 C.F.R. § 11.61) and the FAA 

Modernization and Reform Act of 2012 (FMRA), Section 333, Special Rules for Certain Unmanned Aircraft Systems, 

hereby petitions the Administrator to commercially operate the DJI inspire 

1 UAS in the National Airspace System (NAS), and for an exemption from the requirements of 14 C.F.R §§ 61.113(a) & 

(b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) &(a)(2), and 

91.417(a) & (b). 

In consideration of the speed, weight, size, and limited operating area associated with the unmanned aircraft and its 

operation, Fiycam operation of DJI Inspire 1 UAS meets the conditions of FMRA Section 333 and therefore, will not 

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

C! 
Accordingly, Flycam requests relief from Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) &(a)(2), and 91.417(a) &(b), as 

these sections set forth requirements for maintenance that only apply to aircraft with an airworthiness certificate. 

Flycam submits that the requested relief is proper since an equivalent level of safety will be ensured. Flycam will use 

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

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

Inspire 1 Instruction Manual). 

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

Relief from certain requirements of Section 61.113(a) and (b), entitled Private pilot privileges and limitations: Pilot in 

command, is requested by Flycam to the extent necessary to allow a Pilot in Command (PIC) holding a private pilot or 

higher level certificate, as well as an airman medical certificate, and who has demonstrated, by meeting minimum flighthour and currency requirements, that the PIC is able to safely operate the DJI Inspire 1 UAS in a manner consistent with 

this exemption, including evasive and emergency maneuvers and maintaining appropriate distances from people, 

vessels, vehicles and structures. 

Flycam seeks relief from Section 913(a), entitled Civil aircraft airworthiness, because the DJI Inspire 1 

UAS do not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. As such, Flycam submits 

that it will ensure that the DJI Inspire 1 UAS are in an airworthy condition, prior to every flight, by determining that the 

UAS are in compliance with the operating documents (i.e., Monthly Maintenance Log, and D11 Inspire 1 Instruction 

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

Flycarn also seeks an exemption from the requirements of Section 91.121, entitled Altimeter5ettings, as the DJI Inspire 1 

UA will not have a typical barometric altimeter onboard. However, altitude information of the D11 Inspire 1 UA will be 

provided to the PIC via Global Positioning System (GPS) equipment and radio communications telemetry data link, which 

downlinks from the UA to the GCS for active monitoring of the flight path. This altitude information, combined with 

Flycam's operation of the DJI Inspire 1 UAS within visual line of sight, at or below 500 feet AGL, will ensure a level of 

safety equivalent to Section 91.121. 

Additionally, Flycam seeks an exemption from the requirements of Section 91.151(b), entitled Fuel requirements for 

flightin VfR conditions. Flycam submits that safety will not be affected by operation of the DJI Inspire 1 UA during 

daylight hours in visual meteorological conditions (VMC) under visual flight rules (VFR), with enough battery power to fly 

for a total duration of approximately 13.5 minutes to the first point of intended landing and, assuming normal cruising 

speed, to fly after that for at least 4.5 minutes. 

In accordance with 14 C.F.R. § 11.81, Flycam provides the following information in support of its petition for exemption: 
A. Name And Address Of The Petitioner. 

The name and address of the petitioner and point of contact is: 

Flycam, LLC 

Attn: Roland Lyons & Andy Anderson 

804 N 155t" Ave 

Omaha, Ne 68154 

Phone: 402-913-6331 or 402-740-3401 

Email: Rlyonsa@cox.net 

Email: kaan@cox.net 

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

1. Flycam Seeks Exemption From The Requirements Of Section 61.113(a) And (b). 

Section 61.113, entitled Private pilot privileges and limitations: Pilot in comr»ond, subsections (a) and (b) 

prescribe the following, in relevant part: 

(a) No person who holds a private pilot certificate may act as a pilot 1n command (PIC) of an aircraft that is 

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

hire, act as PIC of an aircraft. 

(b) A private pilot may, for compensation or hire, act as PIC of an aircraft in connection with any business 

or employment if— 

(1) The flight is only incidental to that business or employment; and 

(2) The aircraft does not carry passengers or property for compensation or hire. 

2. Flycam Seeks Exemption From The Requirements Of Section 91.7(a). 

Section 91.7, entitled Civil oircroft oirworthiness, subsection (a), states the following: (a) No person 

may operate a civil aircraft unless it is in an airworthy condition. 

3. Flycam Seeks Exemption From The Requirements Of Section 91.121. 

Section 91.121, entitled Altimeter settings, subsection (a), states the following, in part: 

(a) Each person operating an aircraft shall maintain the cruising altitude or flight level of that aircraft, as 

the case may be, by reference to an altimeter that is set, when operating-- 

(1) Below 18,000 feet MSL, to-- 

(i) The current reported altimeter setting of a station along the route and within 100 nautical miles of 

the aircraft; 

(ii) If there is no station within the area prescribed in paragraph (a)(1)(i) of this section, the current 

reported altimeter setting of an appropriate available station; or 

(iii) In the case of an aircraft not equipped with a radio, the elevation of the departure airport or an 

appropriate altimeter setting available before departure. 

4. Flycam Seeks Exemption From The Requirements Of Section 91.151(b). 

Section 91.151, entitled Fuel requfrements for flight in VFR conditions, subsection (b), states the following: 
(b) No person may begin a flight in a rotorcraft under VFR conditions unless (considering wind and 

forecast weather conditions) there is enough fuel to fly to the first point of intended landing and, 

assuming normal cruising speed, to fty after that for at least 20 minutes. 

S. Flycam Seeks Exemption From The Requirement Of Section 91.405(a). 

Section 91.405, entitled Maintenance required, subsection (a), states the foilowing: Each owner or operator 

of an aircraft— 

(a) Shall have that aircraft inspected as prescribed in subpart E of this part and shatl between required 

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

prescribed in part 43 of this chapter(.J 

6. Flycam Seeks Exemption From The Requirements Of Section 91.407(a)(1) 

Section 91.407, entitled Operation after maintenance, preventive maintenance, rebuilding, or alteration, 

subsection (a)(1), states the following: 

(a) No person may operate any aircraft that has undergone maintenance, preventive maintenance, 

rebuilding, or alteration unless-- 

(1) lt has been approved for return to service by a person authorized under § 43.7 of this chapter(.J 

7. Flycam Seeks Exernption From The Requirements Of Sections 91.409(a)(1) And 

91.409(a)(2). 

Section 91.409, entitled lnspections, subsection (a), states the following: 

(a) Except as provided in paragraph (c) of this section, no person may operate an aircraft unless, within 

the preceding 12 catendar months, it has had -- 

(1) An annual inspection in accordance with part 43 of this chapter and has been approved for 

return to service by a person authorized by § 43.7 of this chapter; or 

(2) An inspection for the issuance of an airworthiness certificate in occordance with part 21 of this 

chapter. 

8. Flycam Seeks Exemption From The Requirements Of Sections 91.417(a) And 91.417(b). 

Section 91.417, entitled Maintenance records, subsections (a) and (b), state the foNowing: 

(a) Except for work performed in accordance with §§ 91.411 and 91.413, each registered owner or 

operator shall keep the following records for the periods specified in paragraph (b) of this section: 

(1) Records af the maintenance, preventive maintenance, and alteration and records of the 100-hour, 

annual, progressive, and other required or approved inspections, as appropriate, for each aircraft 

(including the airframe) and each engine, propeller, rotor, and appliance of an aircraft. The records 

must include-- 

(i) A description (or reference to data acceptable to the Administrator) of the work performed; and 

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

(iii) The signature and certificate number of the person approving the aircraft for return to service. 

(2) Records containing the following information: 

(i) The total time in service of the airframe, each engine, each propelier, and each rotor. 

7 
(ii) The current status of life-limited parts of each airframe, engine, propeller, rotor, and appliance. 

(iii) The time since last overhaul of all items installed on the aircraft which are required to be overhauled 

on a specified time basis. 

(iv) The current inspection status of the aircraft, including the time since the last inspection required by 

the inspection program under which the aircraft and its appliances are maintained. 

(v) The current status of applicable airworthiness directives (AD) and safety directives including, for each, 

the method of compliance, the AD or safety directive number and revision date. If the AD or safety 

directive involves recurring action the time and date when the next action is required. 

(vi) Copies of the forms prescribed by § 43.9(d) of this chapter for each major alteration to the airframe 

and currently installed engines, rotors, propellers, and appliances. 

(b) The owner or operator shall retain the following records for the periods prescribed: 

(1) The records specified in paragraph (a)(1) of this section shall be retained until the work is repeated or 

superseded by other work or for 1 year after the work is performed. 

(2) The records specified in paragraph (a)(2) of this section shall be retained and transferred with the 

aircraft at the time the aircraft is sold. 

(3) A list of defects furnished to a registered owner or operator under § 43.11 of this chapter shall be 

retained until the defects are repaired and the aircraft is approved for return to service. 

C. The Extent Of Relief Flycam Seeks And The Reason Flycam Seeks The Retief. 

1. Extent Of Relief Flycam Seeks And The Reason Flycam Seeks Reiief From Section 

61.113(a) And (b). 

Relief from Section 61.113(a) and (b) entitled Private pifot privileges and (imitations: Pilot in command, is 

requested to the extent necessary to allow a PIC holding a private pilot or higher ievel certificate, as well as a 

current and valid airman medical certificate, and who has met certain flight-hour and currency 

requirements, to conduct the proposed UAS flight operations for compensation or hire. 

This relief is requested since the limitations set forth in Section 61.113(a) and (b) state that a private pilot 

may, for compensation or hire, act as PIC of an aircraft in connection with any business or employment if: (1) 

The flight is only incidental to that business or employment; and (2) The aircraft does not carry passengers 

or property for compensation or hire. 

As set forth more fully below, Flycam submits that an equivalent level of safety will be maintained because 

no PIC wil) be allowed to operate the D11 Inspire 1 UAS unless that PIC has met certain flight-hour and 

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

manner consistent with the operations specifications as described in this exemption, including evasive and 

emergency maneuvers, as well as maintaining appropriate distances from people, vessels, vehicles and 

structures. 

Further, Flycam submits that all flights of the DJI Inspire 1 UAS, conducted by the PIC pursuant to the grant 

of this Petition: (1) will be incidental to Flycam business; and (2) will not carry passengers or property for 

compensation or hire. 
2. Extent Of Relief Flycam Seeks And The Reason Flycam Seeks Relief From Section 91.7(a). 

Relief from Section 91.7(a) entitled Civil aircraft airworthiness, is requested to the extent required to allow 

Flycam to determine that the DJI Inspire 1 UAS is in airworthy condition prior to every flight by ensuring that 

the UAS is in compliance with the operating documents (i.e., the Monthly Maintenance Log, and DJI Inspire 1 

Instruction Manual). 

Flycam seeks the requested relief because the DJI Inspire 1 UAS does not require an airworthiness certificate 

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

Therefore, Flycam will ensure that the D11 Inspire 1 UAS is in airworthy condition based upon its compliance 

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

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

conditions and limitations below. 

3. Extent Of Relief Flycam Seeks And The Reason Flycam Seeks Relief From Section 91.121. 

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

Inspire 1 UAS, which utilize a barometric pressure sensor, GPS equipment, and a radio communications 

telemetry data link to downlink altitude information from the UA to the PIC at the ground control station 

(GCS). Since the FAA requires that any altitude information concerning UAS operations be reported to air 

traffic control (ATC) in feet above ground level (AGL), Flycam seeks the requested relief because the DJI 

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

pressure or field altitude, before each flight. 

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

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

forth herein, an equivalent levei of safety will be maintained since the D11 Inspire 1 UA are equipped with a 

barometric pressure sensor and GPS equipment, which automatically ensures that a ground level pressure 

setting will be established prior to each flight, and provides the PIC with altitude information of the UA on 

the heads-up display of the GCS. 

4. Extent Of Relief Flycam Seeks And The Reason Flycam Seeks Relief From Section 

91.151(b). 

Relief from Section 91.151(b) entitled Fuel requirements for flight in VFR conditions, is requested to the 

extent required to allow flights of the battery powered DJI Inspire 1 UA during daylight hours in visual 

meteorological conditions (VMC), under visual flight rules (VFR), for a total duration of 13.5 minutes to the 

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

Flycam seeks the requested relief because without an exemption from Section 91.151(b), the flight time 

duration of the battery powered DJI Inspire 1 UA will severely constrain the practicality of any aerial video or 

still photo flight operations that Flycam proposes to conduct pursuant to this Petition. 

Significantly, as set forth below, the technical specifications of the D11 Inspire 1 UAS, the DJI 

17 
Inspire 1 operating documents, and Flycam's proposed operating limitations, ensure that Flycam will safely 

operate the battery powered DJI Inspire 1 UA during daylight hours in visual meteorological conditions 

(VMC), under visual flight rules (VFR), with enough battery power to fly for a total duration of 13.5 minutes 

to the first point of intended landing and, assuming normal cruising speed, to fly after that for at least 4.5 

minutes. 

S. Extent Of Relief Flycam Seeks And The Reason Flycam Seeks Relief From Sections 

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

Since Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) &(a)(2), and 91.417(a) &(b) only apply to aircraft with 

an airworthiness certificate, Flycam requests relief from these Sections because the DJI Inspire 1 UAS does 

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

conditions of FMRA Section 333 for operation without an airworthiness certificate. Accordingly, Flycam will 

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

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

Maintenance Log, and DJI Inspire 1 Instruction Manual). Furthermore, Flycam will document and maintain all 

maintenance records for the D11 Inspire 1 UAS. 

D. The Reasons Why Granting Flycam Request Would Be In The Public Interest; That Is, How It Would Benefit The 

Public As A Whole. 

Granting the present Petition will further the public interest by allowing Flycam to safely, efficiently, and 

economically perform aerial video and photography of construction sites, real estate, and landscape over certain 

areas of the United States. 

Additionally, use of the D11 Inspire 1 UAS will decrease congestion of the NAS, reduce pollution, and provide 

significant benefits to the economy. Notably, the benefits of Flycam's proposed operation of the D11 Inspire 1 UAS 

wili be realized without implicating any privacy issues. 

1. The Public Will Benefit From Decreas®d Congestion Of The NAS. 

The DJI Inspire 1 UA are battery powered and serve as a safe, efficient, and economical alternative to the 

manned aircraft traditionally utilized to obtain aerial imagery. By reducing the amount of manned aircraft 

needed to perform aerial acquisitions, an exemption allowing the use of a DJI Inspire 1 UAS would reduce 

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

life and property in the air and on the ground. 

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

caused by arriving and departing aircraft will be reduced. The DJI Inspire 1 UA does not require an airport to 

takeoff or land. Likewise, a reduction of manned aircraft conducting aerial video and photography missions 

wouid result in fewer aircraft that must be handled by air traffic control during the ground, takeofP, 

departure, arrival, and landing phases of flight operations. 

2. The Public Will Benefit From The Safety And Efbciency Of The D11 Inspire 1 UAS. 

10 
Conducting aerial acquisitions with the DJ1 Inspire 1 UAS, instead of manned aircraft, will greatly benefit the 

public by drastically reducing the levels of air and noise pollution generated during traditional aerial video 

and still photography flight operations. By using battery power and electric motors, the DJI Inspire 1 UAS 

produce no air pollution, and is the most viable environmentally conscious alternative to the cabin class, six 

cylinder internal combustion engine aircraft that are typicaily utilized for aerial video and photography, 

while burning approximately 20-30 gallons per hour of ieaded aviation fuel. The DJI Inspire 1 UA, while 

reducing the carbon footprint of aerial acquisitions, also eliminates noise pollution, as the UA are propelled 

by battery powered electric motors, rather than an internal combustion engine. 

By using the DJI Inspire 1 UAS to perform aerial acquisitions, the substantial risk to life and property in the 

air and on the ground, which is usually associated with traditional manned aircraft flight operations, will be 

substantially reduced or completely eliminated. Aside from the lack of flight crew members located onboard 

the aircraft, the DJI Inspire 1 UA (weighing approximately 6 pounds 7.5 ounces, at maximum gross weights 

with length of 17.3 inches, width of 17.7 inches, and with no fuel on board), has less physical potential for 

collateral damage to life and property on the ground, and in the air, compared to the manned aircraft that 

typically conduct similar operations (weighing approximately 6,000 pounds with a wingspan of 

approximately 42 feet, a length of 34 feet, and a fuel capacity of 180 gallons). 

3. Performing Aerial Video and Photography Operations With The DJI Inspire 1 UAS Wiil Benefit The 

Economy. 

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

manned aircraft to conduct similar aerial operations. As such, operation of the DJI Inspire 1 UAS will allow 

United States based companies, like Flycam, 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 technoiogy in order to remain competitive. Operating the battery powered DJI Inspire 1 UAS 

is one such technology that not only allows companies greater operational flexibility compared to manned 

aircraft, but pravides such flexibiiity without the high operational cost of a traditional manned aircraft. 

By operating the DJ1 Inspire 1 UAS, companies such as Flycam, can remain competitive and profitable, and 

therefore, provide greater job stability to employees and contractors, which will ultimately contribute to 

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

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

and federal tax revenues; and allows companies to invest in research and development in order to remain 

competitive both in the United States and abroad. 

4. There Are No Privacy Issues. 

Similar to the manned aerial acquisition flight operations that have been conducted for decades, Flycam's 

proposed operation of the DJI Inspire 1 UAS will not implicate any privacy issues. Specifically, the DJI Inspire 

1 UAS will be operated only in compliance with operating documents (i.e., the Monthly Maintenance Log, 

and DJI Inspire 1 Instruction Manual) which requires property owner involvement as well as local law 

enforcement notification, and in accordance with the Federal Aviation Regulations, including the minimum 

altitude requirements of 14 C.F.R. § 91.119. 

11 
E. The Reasons Why Granting The Exemption Would Not Adversely Affect Safety, Or How The Exemption Would 

Provide A Level Of Safety At Least Equal To That Provided By The Rule From Which Flycam Seeks Exemption. 

1. Reasons Why The DJI Inspire 1 UA Meet The Conditions Of The FAA Modernization and Reform Act of 

2012 (FMRA) Section 333. 

In consideration of the size, weight, speed, and limited operating area associated with the unmanned 

aircraft and its operation, Flycam operation of the DJI Inspire 1 UAS meet the conditions of FMRA Section 

333, and will not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. 

Section 333 provides authority for a UAS to operate without airworthiness certification and sets forth 

requirements for considering whether a UAS will create a hazard to users of the NAS or the public, or 

otherwise pose a threat to national security. Specifically, FMRA Section 333 states the following, in part: 

(a) In General.--Notwfthstanding any other requirement of this subtitle, and not later than 180 days after the 

date of enactment of this Act, the Secretary of Transportation shall determine if certain unmanned aircraft 

systems may operate safely in the national airspace system before completion of the plan and rulemaking 

required by section 332 of this Act or the guidance required by section 334 of this Act. 

(b) Assessment of Unmanned Aircraft Systems.--in making the determination under subsection (a), the 

Secretary shall determine, at a minimum-- 

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

operational capability, proximity to airports and populated areas, and operation within visual 

line of sight do not create a hazard to users of the national airspace system or the public or pose 

a threat to national security; and 

(2) whether a certificate of waiver, certificate of authorization, or airworthiness certification under 

section 44704 of title 49, United States Code, is required for the operation of unmanned aircraft 

systems fdentified under paragraph (1). 

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

unmanned aircraft systems may operate safel y in the national airspace system, the Secretary shai/ 

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

In seeking this exemption, Flycam submits that the D11 Inspire 1 UAS can operate safely in the NAS pursuant to 

FMRA Section 333, as demonstrated by: (a) the characteristics of the DJI Inspire 1 UAS; (b) the pilot certification 

requirement; and (c) the specific operating limitations. 

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

The D11 Inspire 1 UAS does not create a hazard to users of the NAS or the public, or otherwise pose a 

threat to nationat security considering its size, weight, speed, and operational capability. 

i. Technical Specifications Of The DJI Inspire 1 UAS. 

The technical specifications of the DJI Inspire 1 UAS are set forth by the D11 Inspire 1 Technical 

Specifications, attached hereto as Appendix A. 

12 
ii. The DJI Inspire 1 UAS Autonomous Flight And Navigation Modes Enabie The UAS To Remain 

Within A Defined Operational Area. 

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

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

pages 45-50 of the DJI Inspire 1 User Manuals, attached hereto as Appendix B. 

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

Event Of Loss Of The Control Link Or Navigation. 

V'Vhen the Control Link is lost, the DJI Inspire 1 UA will remain stationary, in flight, for 3 seconds 

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

GCS, the UAs 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. 

A complete description of the Failsafe Functions of the DJI Inspire 1 are set forth at pages 13 

through 15 in the DJI Inspire 1 User Manual, attached hereto as Appendix B. 

iv. The DJI Inspire 1 GCS And Its Operation. 

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

GCS and f{ight control software is provided at pages 40 through 43 of the DJI Inspire 1 User 

Manual. DJI Inspire 1 User Manuals are attached hereto as Appendix B. 

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

Command With A Safety Observer. 

Flycam will only utilize certificated operators to act as a pilot in command (PIC) of the DJI Inspire 1 

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

C. Fiights Of DJI Inspire 1 UAS Will Be Conducted Pursuant To Specif•ic Operating limitations. 

In seeking this exemption, Flycam proposes to commerciaNy operate the DJI Inspire 1 UAS for the 

special purpose of conducting aerial video and photography over certain areas of United States, 

pursuant to the following specific operating limitations: 

Operations authorized by this grant of exemption will be limited to the following aircraft 

described in the operating documents, rotorcraft UAS weighing less than 55 pounds maximum 

gross weight: DJI Inspire 1 Unmanned Aircraft Systems. Proposed operations of any other 

aircraft will require a new petition or a petition to amend this grant. 

2. UAS operations under this exemption will be limited to conducting operations for the purpose of 

aerial video and photography. 

13 
3. The UA may not be flown at an indicated airspeed exceeding 20 knots. 

4. The UA must be operated at an altitude of no more than 500 feet above ground level (AGL), as 

indicated by the procedures specified in the operating documents unless a special request is 

made and approved by ATC. AII altitudes reported to ATC must be in feet AGL. 

5. The UAs must be operated within visual line of sight (VLOS) of the PIC at all times. This requires 

the PIC to be able to use human vision unaided by any 

device other than corrective lenses, as specified on the PIC's FAA-issued airman medicai 

certificate. 

6. The use of first person view (FPV) by the PIC or safety observer (SO) is not permitted. 

7. AII operations must utilize a safety observer (SO). The SO may be used to satisfy the VLOS 

requirement as long as the PIC always maintains VLOS capability. The SO and PIC must be able to 

communicate verbally at all times. Electronic messaging or texting is not permitted during flight 

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

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

functions prescribed in the operating documents. 

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

other air traffic and other ground based obstaclesjobstructions and is not permitted to operate 

the camera or other instruments. 

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

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

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

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

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

outlined in its operating documents. The operator may update or revise its operating 

documents. It is the operator's responsibility to track such revisions and present updated and 

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

and revised documents if it petitions for extension or amendment to the grant of exemption. If 

the operator determines that any update or revision would affect the basis upon which the FAA 

granted the exemption, then the operator must petition for amendment to its grant of 

exemption. The FAA's UAS Integration Office (AFS-80) may be contacted if questions arise 

regarding updates or revisions to the operating documents. 

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

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

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

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

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

aircraft records. 

14 
11. Any UAS that has undergone maintenance or alterations that affect the UAS operation or flight 

characteristics, e.g. replacement of a flight critical component, must undergo a functional test 

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

12. The pre-flight inspection must account for all potential discrepancies, e.g. 

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

the operating documents. 

13. The operator must follow the UAS manufacturer's aircraft/component, maintenance, overhaul, 

replacement, inspection, and life limit requirements. 

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

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

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

time in service, description of work accomplished, and the signature of the authorized person 

returning the UAS to service. 

15. Each UAS operated under this exemption must comply with all manufacturer Safety Bulletins. 

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

against discrepancies discovered between inspections. 

17. The PIC must possess at least a private pilot certificate and at least a current third- class medical 

certificate. 

18. The operator may not permit any PIC to operate unless the PIC meets the operator's 

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

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

emergency maneuvers and maintaining appropriate distances from persons, vessels, vehicles 

and structures. PIC qualification flight hours must be logged in a manner consistent with 14 

C.F.R. § 61.51(b). Flights for the purposes of training the operator's PICs are permitted under the 

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

training sessions. During training, proficiency, and experience-building flights, all persons not 

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

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

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

must be conducted under visual meteorological conditions (VMC). If flight at night is required, a 

special request will be made at the FAA office closest to proposed area of operations. Flights 

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

20. The UA may not operate within 5 nautical miles of an airport reference point as denoted on a 

current FAA-published aeronautical chart unless a letter of agreement with that airport's 

management is obtained, and the operation is conducted in accordance with a NOTAM as 

15 
required by the operator's COA. The letter of agreement with the airport management must be 

made available to the Administrator upon request. 

21. The UA may not be operated less than 500 feet below or less than 2,000 feet horizontally from a 

cloud or when visibility is less than 3 statute miles from the PIC. 

22. If the UA loses communications or loses its GPS signal, it must return to a pre- determined 

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

operating documents. 

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

accordance with the operating documents. 

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

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

and land the UA with 25% battery power remaining. 

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

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

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

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

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

altitude level and potential transponder requirements. 

26. AII aircraft operated in accordance with the exemption must be identified by serial number, 

registered in accordance with 14 C.F.R. part 47, and have identification (N- Number) markings in 

accordance with 14 C.F.R. part 45, Subpart C. Markings must be as large as practicable. 

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

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

government oversight agency requirements. 

28. The documents required fewer than 14 C.F.R. 91.9 and 91.203 must be available to the PIC at 

the Ground Control Station of the UAS any time the UAS is operating. These documents must be 

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

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

activities at all times. 

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

31. Flight operations must be conducted at least 500 feet from all nonparticipating persons (persons 

other than the PIC, SO, operator trainees or essential persons), vessels, vehicles, and structures 

unless: 

16 
a. Barriers or structures are present that sufficiently protect nonparticipating persons from 

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

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

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

operations must cease immediately and/or; 

b. The aircraft is operated near vessels, vehicles or structures where the owner/controller of 

such vessels, vehicles or structures has granted permission and the PIC has made a safety 

assessment of the risk of operating closer to those objects and determined that it does 

not present an undue hazard, and; 

C. Operations nearer to the PIC, 50, operator trainees or essential persons do not present an 

undue hazard to those persons per § 91.119(a). 

32. AII operations shall 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. 

33. Any incident, accident, or flight operation that transgresses the lateral or vertical boundaries of 

the operational area as defined by the applicable COA must be reported to the FAA's UAS 

Integration Office (AFS-80) within 24 hours. Accidents must be reported to the National 

Transportation Safety Board (NTSB) per instructions contained on the NTSB Web site: 

www.ntsb.gov . 

2. Reasons Why An Exemption From The Requirements Of Section 61.113(a) And (b) Would Not Adversely 

Affect Safety. 

Flycam submits that the equivalent level of safety established by Section 61.113(a) and (b) will be 

maintained because no PIC will be allowed to operate the DJI Inspire 1 UAS unless that PIC has 

demonstrated, by meeting minimum flight-hour and currency requirements, that the PIC is able to safely 

operate the DJI Inspire 1 UAS in a manner consistent with the exemption, including evasive and emergency 

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

Considering Flycam's proposed area of operations, and the operating limitations set forthabove; the paraliel 

nature of private pilot aeronautical knowledge requirements to those of commercial pilot requirements (See 

Exemption No. 11062); and the airmanship skills necessary to safely operate the DJI Inspire 1 UAS, Flycam 

submits that the additional manned airmanship experience of a commercially certificated pilot would not 

correlate to the airmanship skills necessary for Flycam's specific proposed flight operations. 

The FAA has previously granted relief from Section 61.113(a) and (b) specific to UAS, in circumstances 

similar, in all material respects, to those presented herein (e.g. Exemption Nos. 11062, 11063, 11064,11065, 

11066, 11067, 11080, 11109, 11110, 11112, 11136, 11138, 11150,11153,11156, 11158, 11159;11160, 

11161). 

Flycam will not allow any PIC to operate the DJI Inspire 1 UAS unless that PIC has demonstrated, by meeting 

minimum flight-hour requirements or the DJI Inspire 1 UAS training and currency requirements, that the PIC 

17 
is able to safely operate the DJI Inspire 1 UAS in a manner consistent with this exemption, including evasive 

and emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles and 

structures. 

Specifically, the PIC must have accumulated and logged, in a manner consistent with 14 C.F.R. § 61.51(b), 25 

hours of total time as a UAS rotorcraft pilot (with a minimum of 5 hours of those hours as a UAS pilot 

operating the same make and model of UAS to be used for operations under the exemption), in addition to 

the hour requirements, the PIC must accomplish 3 takeoffs and landings in the preceding 90 days (for 

currency purposes). 

As in Exemption Nos. 11062, 11138, and 11153, prior documented flight experience that was obtained in 

compliance with applicable regulations will ensure an equivalent level of safety during Flycam's proposed 

operations. The Administrator has held that prior documented flight experience that was obtained in 

compliance with applicable regulations would ensure safe operations, stating as follows: 

In Exemption No. 11062, the FAA required that prior to conducting operations for the purpose of 

motion picture filming (or similar operations), the PIC must have accumulated and logged, in a manner 

consistent with 14 CFR 61.51(b), 25 hours of total time as a UAS rotorcraft pilot including at least 10 

hours logged as a UAS pilot with a multi-rotor UAS. Prior to operations under Exemption No. 11062, 

the P1C must also have accumulated and logged a minimum of 5 hours as a UAS pilot operating the 

same make and model of UAS to be used for operations under the exemptfon. For clarification, the FAA 

considers these minimum hour requirements to be inclusive rather than additive; i.e. 5 hours make and 

model time may be included in the 10 hours of multi-rotor time and the 10 hours may be included in 

the total 25 hours of UAS rotorcraft time. tn addition to the hour requirements, the PfC must 

accomplish 3 takeoffs and landings in the preceding 90 days (for currency purposes). The FAA finds 

that at a minimum, the flight-hour requirements in Exemption No. 11062 are appropriate to practice 

and build proficiency in the skills necessary to safely conduct the petitioner's proposed operations. The 

FAA also finds that prior documented flight experience that was obtained in compliance with 

applicable regulations would satisfy this requirement. Training, proficiency, and experience-building 

flights can also be conducted under the grant of exemption to accomplish the required flight time. 

During training, proficiency, and experience-building flights the PIC is required to operate the UA with 

appropriate distances in accordance with 14 C.F.R 91.119. 

Exemption No. 11138 at page 15. 

Accordingly, Flycam will ensure safe operations by not allowing any PIC to operate the DJI Inspire 1 UAS 

unless that PIC has demonstrated, by meeting minimum flight-hour and currency requirements, that the PIC 

is abie to safely operate the DJI Inspire 1 UAS in a manner consistent with the exemption, including evasive 

and emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles and 

structures. 

3. Reasons Why An Exemption From The Requirements Of Section 91.7(a) Would Not Adversely Affect 

Safety. 

18 
The equivalent level of safety established by Section 91.7(a) will be maintained because prior to every flight, 

Flycam wil) ensure that the DJI Inspire 1 UAS is in an airworthy condition based upon the UAS's compliance 

with its operating documents and as stated in the conditions and limitations herein. 

Additionally, the FAA has previously granted relief from Section 91.7(a) specific to UAS, in circumstances 

similar, in all material respects, to those presented herein (e.g. Exemption Nos. 11062,11063, 11064, 11065, 

11066, 11067, 11080, 11109, 11110, 11112, 11136, 11138,11150, 11153, 11156,11157, 11158, 11159, 

11160, 11161). 

4. Reasons Why An Exemption From The Requirements Of Section 91.121 Would Not Adversely Affect 

Safety. 

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

information of the DJI Inspire 1 UA will be provided to the PIC via GPS equipment and a radio 

communications telemetry data link, which downlinks from the UA to the GCS for active monitoring of the 

flight path and altitude. This altitude information, combined with Flycam's operation of the DJI Inspire 1 UA 

within visual line of sight, at or below 500 feet AGL, will ensure a(evel of safety equivalent to Section 91.121. 

The altitude information will be generated by GPS equipment installed onboard the aircraft. Prior to each 

flight, a zero altitude initiation point is automatically established by the UAS at ground level. 

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

material respects, to those presented herein (e.g. Exemption Nos. 11062, 11063, 11064,11065, 11066, 

11067, 11080, 11109, 11112, 11136, 11138, 11150, 11153, 11156,11157, 11158, 11159, 11160, 11161). 

S. Reasons Why An Exemption From 1'he Requirements Of Section 91.151(b) Would Not Adversely Affect 

Safety. 

A grant of this exemption wouid ensure an equivalent level of safety established by 14 C.F.R. Section 

91.151(b) as a result of (1) the technica) specifications of the DJI Inspire 1 UAS; (2) the limitations on the 

proposed flight operations; and (3) the location of the proposed flight operations. Accordingly, Flycam will 

ensure that it wil) safely operate the battery powered DJI Inspire 1 UA during daylight hours in VFR 

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

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

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

proposed flight operations; and the location of the proposed operations, will ensure an equivalent level of 

safety established by 14 C.F.R. Section 91.151(b). Furthermore, safety will be ensured as the DJI Inspire 1 

UAS provide audible and visual warnings to the PIC at the GCS when the UA experiences low battery voltage, 

the first warning occurring at approximately 33% remaining battery power, and again at approximately 10% 

remaining battery power. At the critically low battery level, the DJI Inspire 1 UAS will descend and land 

automatically. 

Significantly, previous exemptions granted by the FAA concerning Section 91.151 establish that safety is not 

adversely affected when the technical characteristics and operating limitations of the UAS are considered. 

Relief has been granted for manned aircraft to operate at less than the minimums prescribed in Section 

19 
91.151, including Exemption Nos. 2689, 5745, and 10650. Moreover, the FAA has previously granted relief 

from Section 91.151 specific to UAS, in circumstances similar, in all material respects, to those presented 

herein (e.g. Exemption Nos. 8811,10808, 10673, 11042, 11062, 11063, 11064, 11065, 11066, 11067,11080, 

11109, 11110, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161). 

6. Reasons Why An Exemption From The Requirements Of Sections 

91.405(a), 91.407(a)(1), 91.409(a)(1) &(a)(2), And 91.417(a) &(b) Wouid Not Adversely Affect Safety. 

In seeking this exemption, Flycam 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 Flycam will use trained technicians to perform maintenance, 

alterations, or preventive maintenance on the 

UAS using the methods, techniques, and practices prescribed in the operating documents 

(i.e., the Monthly Maintenance Log, and the DJI Inspire 1 Instruction Manual). Furthermore, Flycam will 

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

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

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

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

copy of the DJI Inspire 1 UAS Maintenance Manual and Maintenance Log is attached hereto as Appendix C 

and E, respectively. 

Likewise, the exemption sought will not adversely affect safety because Flycam will use trained technicians 

to perform maintenance, alterations or preventive maintenance on the 

UAS using the methods, techniques, and practices prescribed by the operating documents. 

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

91.407, 91.417(a) and 91.417(b), because all maintenance of the DJI Inspire 1 UAS will be performed by 

trained technicians. Maintenance will be documented and maintained utilizing the monthly maintenance 

log. 

Significantly, previous exemptions granted by the FAA concerning Sections 91.405(a), 

91.407(a)(1), 91.409(a)(1) &(a)(2), and 91.417(a) &(b) establish that safety is not adversely affected when 

the technical characteristics and operating limitations of the UAS are considered. 

In consideration of Flycam's proposed operating limitations, the operating documents, and the technical 

aspects of the DJI Inspire 1 UAS, Flycam submits that safety will not be adversely affected by granting 

exemption from 14 C.F.R. Sections 91.405(a), 91.407(a)(1) and (a)(2), 91.409(a)(2), and 91.417(a) and (b). 

The FAA has previously granted relief specific to UAS in circumstances simiEar, in all material respects, to 

those presented herein (e.g. Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067,11080, 11109, 

11110, 11112, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161). 

Ni7 
7. The FAA May Prescribe Any Other Conditions For Safe Operation. 

In accordance with Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA) and 14 C.F.R. § 

21.16 entitled Specia) Conditions, Flycam requests that the FAA prescribe special conditions for the intended 

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

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

C.F.R §§ 61.113(a) &(b), 91.7 (a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) &(a)(2), and 

91.417(a) &(b). Such special conditions will permit safe operation of the UAs for the limited purpose of 

conducting aerial video and photography over certain areas of the United States for compensation or hire. 

FMRA Section 333 sets forth the requirements for considering whether a UAS will create a hazard to users of 

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

such UAS to operate without airworthiness certification in accordance with any requirements that must be 

established for the safe operation of the UAS in the NAS. 

Likewise, the Administrator may prescribe special conditions pursuant to 14 C.F.R. 

§ 21.16, for operation of the DJI Inspire 1 UAS, since the airworthiness regulations of 14 C.F.R. Part 21 do not 

contain adequate or appropriate safety standards, due to the novel or unusual design features of the 

aircraft. Section 21.16, entitled Special Conditions, states the following: 

If the FAA finds that the airworthiness regulations of this subchapter do not contain adequate or 

appropriate safety standards for an aircraft, aircraft engine, or propeller because of a novel or unusual 

design feature of the aircraft, aircraft engine or propeller, he prescribes special conditions and 

amendments thereto for the product. The special conditions are issued in accordance with Part 11 of 

this chapter and contain such safety standards for the aircraft, aircraft engine or propeller as the FAA 

finds necessary to establish a level of safety equivalent to that established in the regulations. 

See 14 C.F.R. § 21.16. 

Therefore, in accordance with FMRA Section 333 and 14 C.F.R. § 21.16, the FAA may prescribe special 

conditions for Flycam's intended operation of the DJI Inspire 1 UAS, which contain such safety standards 

that the Administrator finds necessary to establish a level of safety equivalent to that established by 14 

C.F.R. Part 21, Subpart H, and 14 C.F.R Sections 61.113(a) &(b), 91.7(a), 91.121, 91.151(b), 91.405(a), 

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

F. A Summary That Can Be Published In The Federal Register, stating: The Rules From Which Flycam Seeks 

Exemption: 

Flycam seeks exemption from the requirements of 14 C.F.R Sections 61.113(a)&(b), 91.7(a), 91.121, 91.151(b), 

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

A Brief Description Of The Nature Of The Exemption Filycam Seeks: 

This exemption will permit Flycam to commercially operate an Unmanned Aircraft System (UAS) for the purpose of 

conducting aerial video and photography over certain areas of the United States. 

21 
G. Any Additional Information, Views, Or Arguments Avaiiable To Support Flycam's Request. 

This Petition is made pursuant to the FAA Modernization and Reform Act of 2012 

(FMRA) Section 333, which directs the Secretary of Transportation to determine if certain UAS may operate safely 

in the NAS. As such, Flycam'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, Flycam will operate the DJI Inspire 1 UAS safely in the NAS, without creating a hazard 

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

CONCLUSION 

As set forth herein, Flycam seeks an exemption pursuant to 14 C.F.R. § 11.61 and Section 333 of the 

FAA Modernization and Reform Act of 2012 (FMRA), which will permit safe operation of the DJI Inspire 1 UAS 

commercially, without an airworthiness certificate, for the limited purpose of conducting aerial video and photography 

over certain areas of the United States. By granting this Petition, the FAA Adrninistrator will be fulfilling the 

Congressional mandate of the FAA Modernization and Reform Act of 2012, while also advancing the interests of the 

public, by allowing Flycam to safely, efficiently, and economically operate the DJI Inspire 1 UAS commercially within the 

NAS. 

WHEREFORE, in accordance with the Federal Aviation Regulations and the FAA Modernization and 

Reform Act of 2012, Section 333, Flycam respectfully requests that the Administrator grant this 

Petition for an exemption from the requirements of 14 C.F.R Sections 61.113(a) &(b), 91.7(a), 91.121, 91.151(b), 

91.405(a), 91.407(a)(1), 91.409(a)(1) &(a)(2), and 91.417(a) &(b), and permit Flycam to operate the DJI Inspire 1 UAS 

commercially for the purpose of conducting aerial video and photography over certain areas of the United States. 

Dated: June 20, 2015 

Respectfully submitted, 

Roland Lyons Andy Anderson 

C✓ , G,~ r~~ 

. 

FLYCAM 

804 N 155t" Ave 

Omaha, Ne 68154 

402-913-6331 or 402-740-3401 

22 
APPENDICES 

APPENDIX — A: DJI Inspire 1 Technical Specifications 

APPENDIX — B: DJI Inspire 1 Manufacturer's User Manual 

APPENDIX — C: DJI Inspire 1 Manufacturer's Maintenance Manual 

APPENDIX — D: DJI Inspire 1 Manufacturer's Safety Guidelines 

23 
APPENDIX — A: DJI Inspire 1 Technical Specifications 

See Attached Document 

24 
APPENDIX — B: DJI Inspire 1 Manufacturer's User Manua) 

See Attached Document 

25 
APPENDIX — C: DJI Inspire 1 Manufacturer's Maintenance Manual 

See Attached Document 

7rn 
APPEIVDIX — D: DJI Inspire 1 Manufacturer's Safety Guidelines 

See Attached Document 

27