Petition for Exemption 14 CFR § 11.81

If you have completed your research and determined you need an exemption, you must send a petition 

for exemption 120 days before you need the exemption to take effect. Your petition for exemption must 

include—

A.) Your name and mailing address. You may include other contact information such as a fax 

number, telephone number, or email address;

Bryan Stewart

Media Stew, LLC

PO Box 5048

Incline Village, NV 89450

775-721-9714

bryan@mediastew.tv

B.) The specific section or sections of 14 CFR from which you seek an exemption;

1. Section 61.113, entitled Private pilot privileges and limitations: Pilot in command, 

subsections (a) and (b).

(a) No person who holds a private pilot certificate may act as pilot in command of an 

aircraft that is carrying passengers or property for compensation or hire; nor may 

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

(b) A private pilot may, for compensation or hire, act as pilot in command 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. Section 91.7, entitled Civil aircraft airworthiness, subsection (a).

(a) No person may operate a civil aircraft unless it is in an airworthy condition. 

3. Section 91.121, entitled Altimeter settings, subsection (a).

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

(b).

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

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

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

after that for at least 20 minutes.

5. Section 91.405, entitled Maintenance required, subsection (a)

Each owner or operator of an aircraft -

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

between required inspections, except as provided in paragraph (c) of this section, 

have discrepancies repaired as prescribed in part 43 of this chapter.

6. Section 91.407, entitled Operation after maintenance, preventive maintenance, 

rebuilding or alteration, subsection (a)(1).

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

maintenance, rebuilding or alteration unless –

(1) It has been approved for return to service by a 

person authorized under Section 43.7 of this 

chapter.

7. Section 91.409, entitled Inspections, subsection (a)(1) and (a)(2).

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

aircraft unless, within the preceding 12 calendar months, it has had –

(1) An annual inspection in accordance with part 43 

of this chapter and has been approved for return 

to service by a person authorized by Section 

43.7 of this chapter; or

(2) An inspection for the issuance of an 

airworthiness certificate in accordance with part 

21 of this chapter. 

8. Section 91.417, entitled Maintenance records, subsection (a) and (b).

(a) Except for work performed in accordance with Section 91.411 and 91.413, each 

registered owner or operator shall keep the following records for the periods 

specified in paragraph (b) of this section:

1. Records of the maintenance, preventive maintenance, and alteration and 

records of the 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 

propeller, and each rotor.

(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 directions 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 Section 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 

Section 43.11 of chapter shall be retained until the defects are repaired 

and the aircraft is approved for return to service. 

C.) The extent of relief you seek and the reason you seek the relief;

1. Relief from Section 61.113 (a) and (b) entitled Private pilot privileges and 

limitations: Pilot in command, is requested to the extent necessary to allow a PIC 

holding a private pilot certificate, a third-class airman medical certificate and has 

completed the minimum hours and cycles as a UAS rotorcraft pilot to conduct the 
proposed UAS flight operations for compensation. The 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, Media Stew, LLC submits that an equivalent level of safety 

will be maintained because no PIC will be allowed to operate the DJI Inspire I UAS 

unless that PIC has demonstrated that the PIC is able to safely operate the DJI Inspire I 

UAS in a manner consistent with the DJI Inspire I Flight Manual and 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, Media Stew, LLC submits that all flights of the DJI Inspire I UAS, conducted by 

the PIC pursuant to the grant of this Petition – (1) will be incidental to Media Stew’s 

business; and (2) will not carry passengers or property for compensation or hire. 

2. Relief from Section 91.7(a) entitled Civil aircraft airworthiness, is requested to the 

extent required to allow Media Stew, LLC to determine that the DJI Inspire I UAS is in an 

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

DJI Inspire I Flight Manual, and that the aircraft is in a condition for safe flight. 

Media Stew, LLC seeks the requested relief because the DJI Inspire I UAS does not 

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

Therefore, Media Stew, LLC will ensure that the DJI Inspire I UAS is in an airworthy 

condition based upon its compliance with the operating documents (i.e., the DJI Inspire I 

Flight Manual) prior to every flight, and as stated in the conditions and limitations below.

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

operations of the DJI Inspire I UAS, which utilizes GPS equipment and a radio 

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

UA to the Ground Control System. As more fully set forth below, safety will be maintained 

as a result of the DJI Inspire I UA’s altitude readout via GPS equipment, and Media Stew 

LLC’s operation of the DJI Inspire I UA within visual line of sight, at or below 400 feet 

AGL. 

4. 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 I UA during daylight hours in visual meteorological conditions (VMC), under visual 

flight rules (VFR) conditions, to continue for a total duration of 10 minutes, which will 

ensure that the UA will land with five minutes of batter power remaining. Media Stew, 

LLC seeks the requested relief because without an exemption from Section 91.151(b), 

the flight time duration of the battery powered DJI Inspire I UA will severely constrain the 
practicality of any aerial industrial video footage acquisition that Media Stew, LLC 

proposes to conduct pursuant to this Petition. 

Significantly, as set forth below, the technical specification of the DJI Inspire I UAS, it’s 

flight manual, and Media Stew, LLC’s proposed operating limitations, ensure that Media 

Stew, LLC will safely operate the battery powered DJI Inspire I UA during daylight hours 

in VFR conditions, for a total flight duration of 10 minutes, landing with five minutes of 

batter power remaining.

5. 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, Media Stew LLC requests relief 

from these Sections because the DJI Inspire I UAS does not require an airworthiness 

certificate. As set forth more fully below, the DJI Inspire I UAS meets the conditions of 

Section 333 of the FMRA for operation without an airworthiness certificate. Accordingly, 

Media Stew, LLC will use authorized technicians to perform maintenance, alterations, or 

preventive maintenance on the UAS using methods, techniques and practices prescribed 

in the manufacturer’s maintenance manual. Furthermore, Media Stew, LLC will 

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

D.) How your request would benefit the public as a whole;

Granting the present Petition will further the public interest by allowing Media Stew, LLC to safely, 

efficiently, and economically acquire aerial industrial video, commercially, in support of industrial 

video production. Additionally, use of the DJI Inspire I UAS will decrease congestion of the 

National Air Space, reduce pollution, and provide significant benefits to the economy. Notably, the 

benefits of Media Stew, LLC’s proposed operation of the DJI Inspire I UAS will be realized without 

implicating any privacy issues. 

1. Media Stew, LLC submits this Petition to commercially operate the DJI Inspire I UAS with 

the intention of acquiring aerial footage to be used in industrial video production. The DJI 

Inspire I UAS will provide a safe, efficient and economical way to acquire this footage, by 

having a licensed private pilot, who meets all the necessary qualifications, flying within 

the guidelines set by the FAA. This would allow access, to small and medium sized 

business owners, of high quality footage not normally accessible to these business 

owners who are looking to increase their reach and customer base with marketing 

materials.

2. The Public will benefit from decreased congestion of the National Air Space. The DJI 

Inspire I UAS is battery powered and serves as a safe, efficient, and economical 

alternative to the manned aircraft traditionally utilized to obtain aerial footage. By 

reducing the amount of manned aircraft needed to acquire aerial footage, an exemption 

allowing the use of a DJI Inspire I UAS would reduce the amount of manned aircraft in 

the National Air Space, reduce the 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 National Air Space, congestion around airports caused 

by arriving and departing aircraft will be reduced. The DJI Inspire I UAS does not require 

an airport to takeoff or land. Likewise, a reduction of manned aircraft would result in fewer 

aircraft that must be handled by air traffic control during the ground, takeoff, departure, 

arrival and landing phases of flight operations. 

3. Conducting video acquisitions with the DJI Inspire I 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 footage acquisition flight operations. By using 

battery power and electric motors, the DJI Inspire I UAS produces no air pollution, and is 

the most viable environmentally conscious alternative to the cabin class, six cylinder 

internal combustion twin engine aircraft that are typically utilized for aerial acquisitions, 

while burning approximately 20-30 gallons per hour of leaded aviation fuel. The DJI 

Inspire I UA, while reducing the carbon footprint of aerial video footage acquisitions, also 

eliminates noise pollution, as the UA is propelled by battery powered electric motors, 

rather than an internal combustion engine.

By using the DJI Inspire I to perform aerial video footage 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 I UA (weighting approximately 6.5 Pounds at its maximum gross weight with a 

diameter of 18 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 aerial acquisitions (Weighting approximately 6,500 pounds 

with a wingspan of approximately 40 feet, a length of 34 feet, and a fuel capacity of 180 

gallons).

4. Performing aerial video footage acquisition with the DJI Inspire I will benefit the economy. 

In addition to being safe and efficient, the DJI Inspire I UAS is also an economical 

alternative to using manned aircraft to conduct aerial footage acquisitions. As such, 

operation of the DJI Inspire I UAS will allow Media Stew, LLC to remain competitive and 

contribute to the growth of the US economy. Specifically, with the rising cost of aviation 

fuel and the EPA regulatory actions phasing out leaded aviation fuels, US owned and 

operated companies must adopt new and alternative technology in order to remain 

competitive. Operating the battery powered DJI Inspire I UAS is one such technology that 

not only allows companies greater operational flexibility compared to manned aircraft, but 

provides such flexibility without the high operational cost of a traditional manned aircraft. 

By operating the DJI Inspire I UAS, companies such as Media Stew, LLC can remain 

competitive and profitable, and therefore, provide greater job stability to employees and 

contractors, which will ultimately contribute to growth of the US economy. Improved 
financial performance of US companies, through commercial use of the DJI Inspire I

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. 

5. There are no Privacy Issues. Similar to the manned aerial acquisition flight operations 

that have been conducted for decades, Media Stew, LLC’s proposed operation of the DJI 

Inspire I UAS will not implicate any privacy issues. Specifically, the DJI Inspire I UAS will 

be operated only in accordance with all Federal Aviation Regulations, including the 

minimum altitude requirements of 14 C.F.R. Section 91.119. Most significantly, the DJI 

Inspire I UA will not be operated closer than 500 feet to any person, vessel, vehicle, or 

structure, which is not directly involved in the operation.

E.) Reasons why the exemption would not adversely affect safety, or how the exemption 

would provide a level of safety at least equal to the existing rule;

1. Reasons why the DJI Inspire I UAS meets 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, Media 

Stew LLC’s operation of the UAS meets 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.—Nothwithstanding 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, as 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 
requires for the operation of unmanned aircraft 

systems identified under paragraph (1).

(c) Requirements for Safe Operation. – If the Secretary determines under this 

section that certain unmanned aircraft systems may operate safely in the national 

airspace system, the Secretary shall establish requirements for the safe 

operation of such aircraft systems in the national airspace system. 

In seeking this exemption, Media Stew, LLC submits that the DJI Inspire I UAS can 

operate safely in the NAS pursuant to FMRA Section 333, as demonstrated by: (a) the 

characteristics of the DJI Inspire I UAS; (b) the pilot certification requirement; and (c) the 

specific operating limitations.

(a) The DJI Inspire I UAS does not create a hazard to users of the NAS or the 

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

weight speed and operational capability. The UAS Flight and Navigation 

Modes Enable the UAS to remain within a Defined Operational Area. The 

UAS is designed for Automatic return to launch in the event of loss of the 

control link or navigation

(b) Flight operations of the UAS are limited to the Line of Sight of a certificated 

PIC with a safety observer. Media Stew, LLC will only utilize certificated pilots 

who possess a valid airman medical certificate to act as a pilot in command

of the UAS. Additionally, a safety observer will assist all pilots.

(c) Flights of the DJI Inspire I UAS will be conducted pursuant to specific 

operating limitations. In seeking this exemption, Media Stew LLC proposes to 

commercially operate the DJI Inspire I UAS for the special purpose of 

obtaining industrial aerial footage pursuant to the following specific operating 

limitations:

(1) Operations authorized by this grant of exemption 

are limited to a quad rotor aircraft weighting less 

than 10 pounds. Proposed operations of any 

other aircraft will require a new petition or a 

petition to amend this grant.

(2) The UA may not be flown at an indicated 

airspeed exceeding 43.4 knots.

(3) The UA must be operated at an altitude of no 

more than 400 feet above ground level (AGL). 

All altitudes reported to ATC must be in feet 

AGL.

(4) The UA 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 medical certificate. 
(5) All operations must utilize a visual observer 

(VO). The VO may be used to satisfy the VLOS 

requirement, as long as the PIC always 

maintains VLOS capability. The VO and PIC 

must be able to communicate verbally at all 

times. The PIC must be designated before the 

flight and cannot transfer his or her designation 

for the duration of the flight.

(6) The operator’s manual and this grant of 

exemption must be maintained and made 

available to the Administrator upon request. If a 

discrepancy exists between the conditions and 

limitations in this exemption and the procedures 

outlined in the operator’s manual, the conditions 

and limitations herein take precedence and must 

be followed. Otherwise, the operator must follow 

the procedures as outlined in its operator’s 

manual. The operator may update or revise its 

operator’s manual. 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. If the 

operator determines that any update or revision 

would affect the basis upon which the FAA 

granted this exemption, then the operator must 

petition for amendment to their exemption. The 

FAA’s UAS Integration Office (AFS-80) may be 

contacted if questions arise regarding updates 

or revisions to the operator’s manual.

(7) Prior to each flight the PIC must inspect the UAS 

to ensure it is in a condition for safe flight. If the 

inspection reveals a condition that affects the 

safe operation of the UAS, the aircraft is 

prohibited from operating until the necessary 

maintenance has been performed and the UAS 

is found to be in a condition for safe flight. The 

Ground Control Station must be included in the 

preflight inspection. All maintenance and 

alterations must be properly documented in the 

aircraft records. 

(8) 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 in accordance with the operator’s 

manual. The PIC who conducts the functional 

test flight must make an entry in the UAS aircraft 

records of the flight. The requirements and 

procedures for a functional test flight and aircraft 

record entry must be added to the operator’s 

manual.

(9) The preflight inspection must account for all 

discrepancies, i.e. inoperable components, 

items, or equipment, not covered in the relevant 

preflight inspection sections of the operator’s 

manual.

(10) The operator must follow the manufacturer’s 

UAS aircraft/component, maintenance, overhaul, 

replacement, inspection, and life limit 

requirements, with particular attention to flight 

critical components that may not be addressed 

in the manufacturer’s manuals.

(11) Media Stew, LLC must carry out their 

maintenance, inspections, and record keeping 

requirements in accordance with the operator’s 

manual. Maintenance, inspection, and 

alterations must be noted in the aircraft logbook, 

including total flight hours, description of work 

accomplished, and the signature of the 

authorized UAS technician or PIC returning the 

UAS to service.

(12)Each UAS operated under this exemption must 

comply with all manufacturer System and Safety 

Bulletins.

(13)The PIC must possess at least a private pilot 

certificate and a third-class airman medical 

certificate. 

(14)The operator may not permit any PIC to operate 

unless that PIC has demonstrated, through the 

training and currency requirements set forth in 

the operator’s manual, that the PIC is able to 

safely operate the UAS in a manner consistent 

with how the UAS will be operated under this 

exemption including evasive and emergency 

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

structures.

(15)UAS operations may not be conducted during 

night, as defined in 14 C.F.R. Section 1.1. All 

operations must be conducted under visual 

meteorological conditions (VMC). Flights under 

special visual flight rules (SVFR) are not 

authorized.

(16)The UA may not operate within 5 nautical miles 

of the airport reference point as denoted on a 

current FAA-published aeronautical chart.

(17)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.

(18)If the UAS loses communications or loses its 

GPS signal, the UA must return to a predetermined location within the private or 

controlled access property and land, or be 

recovered in accordance with the operator’s 

manual.

(19)The PIC must abort the flight in the event of 

unpredicted obstacles or emergencies in 

accordance with the operator’s manual.

(20)The PIC is prohibited from beginning a UAS 

flight unless (considering wind and forecast 

weather conditions and assuming normal 

cruising speed) there is enough power to fly to 

the first point of intended landing prior to utilizing 

battery reserve power.

(21)All aircraft operated in accordance with this 

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 practical.

(22)Before conducting operations, the radio 

frequency spectrum used for operation and 

control of the UA must comply with the Federal 

Communication Commission (FCC) or other 

appropriate government oversight agency 

requirements.

(23)The documents required under 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 

aircraft is operating. These documents must be 

made available to the Administrator or any law 

enforcement official upon request.

(24)The UA must remain clear and yield the right of 

way to all other manned aviation operations and 

activities at all times.

(25)The UAS may not be operated by the PIC from 

any moving device or vehicle.

(26)The UA may not be operated over congested or 

densely populated areas. These areas include 

but are not limited to the yellow areas depicted 

on World Aeronautical Chars (WAC), Sectional 

Aeronautical Charts (Sectionals), or Terminal 

Area Charts (TAC). However, aeronautical 

charts may not reflect pertinent local information. 

Ultimately it is the PIC’s responsibility to 

maintain the minimum safe altitudes required by 

Section 91.119.

(27)Flight operations must be conducted at least 500 

feet from all non-participating persons (persons 

other than the PIC or VO), vessels, vehicles, 

and structures unless:

a. Barriers or structures are present that 

sufficiently protect nonparticipating 

persons from 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 land 

owner/controller has granted permission 

and the PIC has made a safety 

assessment of the risk of operating 

closer to those objects and;

c. Operations near the PIC or VO do not 

present an undue hazard to the PIC or 

VO, per Section 91.119(a). 

(28)All 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 prior to the beginning of every flight.

(29)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. Media Stew LLC 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 I UAS unless that PIC has demonstrated that the PIC 

is able to safely operate the DJI Inspire I UAS in a manner consistent with this exemption, 

including evasive and emergency maneuvers and maintaining appropriate distances from 

people, vessels, vehicles and structures.

Considering Media Stew LLC’s proposed area of operations, and the operating limitations 

set forth-above; the parallel nature of private pilot aeronautical knowledge requirements 

to those of commercial pilot requirements; and the airmanship skills necessary to safely 

operate the DJI Inspire I UAS, Media Stew, LLC submits that the additional manned 

airmanship experience of a commercially certified pilot would not correlate to the 

airmanship skills necessary for Media Stew, LLC’s specific proposed flight operations. 

3. Reasons why an exemption from the requirements of Section 91.7(a) would not 

adversely affect safety: The equivalent level of safety established by Section 91.7(a) will 

be maintained because prior to every flight, Media Stew, LLC will ensure that the DJI 

Inspire I UAS is in an airworthy conditions based upon the DJI Inspire I UAS’s 

compliance with its operating documents, and as stated in the conditions and limitations 

herein. 

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 I 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. This altitude information, 

combined with Media Stew LLC’s operation of the DJI Inspire I UA within visual line of 

sight, at or below 400 feet AGL, will ensure a level of safety equivalent to Section 91.121. 
The altitude information will be generated by GPS equipment installed onboard the 

aircraft. Prior to each flight, a zero altitude initiation point will be established and 

confirmed for accuracy by the UAS PIC. 

5. Reasons why an exemption from requirements of Section 91.151(b) would not adversely 

affect safety: A grant of this exemption would ensure an equivalent level of safety 

established by 14 C.F.R. Section 91.151(b) as a result of (1) the technical specifications 

of the DJI Inspire I UAS; (2) the limitations on the proposed flight operations; and (3) the 

location of the proposed flight operations. Accordingly, Media Stew, LLC will ensure that 

it can safely operate the battery powered DJI Inspire I UA during daylight house, in VFR 

conditions, for a total flight duration of no more than 10 minutes, resulting in a landing 

with five minutes of battery power remaining.

In the event that the UAS should run out of power, it would simply land within the access 

controlled operating area. Given its weight and construction material, the risks are less 

than contemplated by the current regulation. The DJI Inspire I provides a battery failsafe 

that commands the UA’s return to the launch point when critical minimum voltage is 

reached. The UAS batteries provide approximately 15 minutes of powered flight. Given 

the limitations on its proposed operations and the location of those proposed operations, 

a reduced minimum power reserve for flight in daylight VFR conditions is reasonable.

6. Reasons why an exemption from the requirements of Sections 91.405 (a), 91.407 (a)(1), 

91.409 (a)(1) & (a)(2), and 91.417 (a) & (b) would not adversely affect safety: In seeking 

this exemption, Media Stew LLC 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 Media 

Stew LLC will use trained technicians to perform maintenance, alterations, or preventive 

maintenance on the unmanned aircraft system. Furthermore, Media Stew, LLC will 

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

Since the DJI Inspire I UAS will be inspected as prescribed by the manufacturer’s 

maintenance manual, Media Stew, LLC will maintain the equivalent level of safety 

established by Sections 91.405(a), 91.409(a)(1), and 91.409(a)(2). The flight manual for 

the DJI Inspire I UAS sets forth airworthiness requirements for the UA, including preflight 

and post flight inspections, as well as scheduled maintenance in four categories: daily, 

weekly, monthly and yearly. Likewise, the exemption sought will not adversely affect 

safety because Media Stew, LLC will perform maintenance, alterations or preventive 

maintenance on the UAS using the methods, techniques, and practices prescribed by the 

manufacturer’s maintenance manual. The Flight manual for the DJI Inspire I UAS details 

procedures for each component of the UA, including the components of the propulsion 

system, avionics system and payload system.

In consideration of Media Stew, LLC’s proposed operating limitations, the most recent 
DJI Inspire I Manual, and the technical aspects of the DJI Inspire I UAS, Media Stew, 

LLC submits that safety will not be adversely affected by granting exemption from 14 

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

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

material respects, to those presented herein.

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. 

Section 21.16 entitled Special Conditions, Media Stew, LLC requests that the FAA 

prescribe special conditions for the intended operation of the DJI Inspire I UAS, which 

contain such safety standards that the Administrator finds necessary to establish a level 

of safety equivalent to that established by 14 CFR Part 21, Subpart H, and 14 CFR 

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). Such special conditions will permit safe 

operation of the UA for the limited purpose of conducting aerial industrial footage 

acquisitions over certain areas of the United States. 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 CFR Section 

21.16, for operation of the DJI Inspire I UAS, since the airworthiness regulations of 14 

CFR 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 that 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. 

Section 21.16.

Therefore, in accordance with FMRA Section 333 and 14 CFR Section 21.16, the FAA 

may prescribe special conditions for Media Stew, LLC intended operation of the DJI 

Inspire I 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 we can publish in the Federal stating—

The Rules from which Media Stew LLC seeks exemption:

Media Stew, LLC seeks exemption from the requirements of 14 CFR Sections 61.113(a) & (b), 

91.7 (a), 91.121, 91.151(b), 91.405 (a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417 (a) & (b).

A. Brief Description of the nature of the Exemption Media Stew, LLC seeks:

This exemption will permit Media Stew LLC to commercially operate an Unmanned Aircraft 

System (UAS) for the purpose of acquiring aerial industrial video footage, commercially, in 

support of small to medium sized business to be used in marketing materials over specific 

property in the United States.

G.) Any additional information, views, or arguments available to support your 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 NAS. As such, Media Stew, LLC’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, Media Stew, LLC will operate the DJI Inspire I 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.

As set forth herein, Media Stew, LLC seeks an exemption pursuant to 14 CFR Section 11.61 and 

Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA), which will permit safe 

operation of the DJI Inspire I UAS commercially, without an airworthiness certificate, for the 

limited purpose of conducting aerial industrial footage acquisitions, commercially, in support of

small to medium sized business to be used in marketing materials over specific property in the 

United States. By granting this petition, the FAA Administrator will be fulfilling the congressional 

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

the public, by allowing Media Stew, LLC to safely, efficiently, and economically operate the DJI 

Inspire I commercially within the NAS.

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

Reform Act of 2012, Section 333, Media Stew, LLC respectfully request that the Administrator 

grant this Petition for an exemption from the requirements of 14 CFR 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 Media Stew, LLC to operate the DJI Inspire I UAS commercially for the purpose of 

conducting aerial industrial footage acquisitions, commercially, in support of small to medium 

sized business to be used in marketing materials over specific property in the United States.

H.) If you want to exercise the privileges of your exemption outside the United States, you 

must state the reason. N/A