KZ

Aerial	Photography	

12505	Spring	Drive

Manassas,	VA	20112

14	September	2015

US	Department	of	Transportation	

Docket	Management	System	

1200	New	Jersey	Ave.,	SE	

Washington,	DC	20590	

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

of	the	Federal	Aviation	Regulations

To	Whom	It	May	Concern:

Pursuant	to	Section	333	of	the	FAA	Modernization	and	Reform	Act	of	2012	

and	the	requirements	contained	within	14	C.F.R.	Part	11,	Kevin	Zawistowski	(KZ)	

Aerial	Photography requests	an	exemption	from	Federal	Aviation	Regulations	

(FARs)	detailed	below	for	the	DJI	Inspire 1 unmanned	aerial	system (UAS).

Often	private	companies	obtain	such	photography	products	illegally,	creating	

a	hazard	to	air	traffic, public	safety and	even	national	security.	KZ	Aerial	

Photography seeks	to	mitigate	this	by	providing safe,	legal	and	invaluable aerial	

photography	and	cinematography	to	its	customers.	

Aircrew consists of	a	pilot	in	command	(PIC)	and	a	visual	observer	(VO).	Our	

primary	PIC	holds	a	commercial	rotorcraft	certificate	with	instrument	helicopter	

rating.	Additionally	our	primary	pilot	is	a	U. S.	Army	veteran	and	Blackhawk	

helicopter	pilot	with	one	combat	tour	in	Afghanistan.	Our	back-up	PIC	holds	a	

private	pilot’s	certificate	with	single-engine	land	rating.	 Both	PICs	have	a	spotless	

FAA	safety	record. All	VOs	train	along	side	PIC	and	remain	within	talking	distance	of	

PIC. Both	PIC	and	VO	wear	clearly	marked	high	visibility	vests	identifying	them	as	

aircrew	of	the	UV. The	PIC	and	VO	will	meet	the requirements	outlined	in	the	FAA	

Policy	N	8900.227	Section	16	Personnel	Qualifications.

Our	Unmanned	Vehicle	(UV)	used is the	DJI	Inspire	1.	This	system	is reliable,	

tested	and	commercial	off-the-shelf	requiring	minimal	assembly,	lowering	any	

chance	of	structural	failure	of	UV.		PIC	and	VO	in	accordance	with	the	DJI	Inspire1	
Maintenance	Manual	will	maintain	the	UV. DJI	Safety	guidelines	will	be	adhered	to	at	

all	times.

The	unmanned	aircraft	included	in	this	exemption	will	be	operated	in	the	

field	with	both	a	Pilot	in	Command	(PIC)	and	a	ground-based	Visual	Observer	(VO)	

in	accordance	with	the	FAA	Policy	N	8900.227	Section	14	"Operational	

Requirements	for	UAS"	with	the	following	additional	operating	restrictions:	

1. All	operations	will	occur	in	Class	G	airspace	at	no	more	than	400ft	AGL	

and	at	speed	less	than	50kts.

2. All	required	permits	and	permissions will	be	obtained	from	state	and	

local	government	and	land	owners	prior	to	operation	and	local	

authorities	notified.

3. The	UV will	not	be	operated	over	urban	or	populated	areas.

4. The	UV	will	not	be	operated	over environmentally	sensitive	areas.

5. The	UV	will	not	be	operated	at	air	shows	or	over	an	open-air	assembly	of	

people.

6. The	UV will	not	be	operated	over	public	roadways	or	trails.

7. Operations	will	be	limited	to	VMC	only,	maintaining	all	basic	weather	

minima.	

8. Aircraft	will	remain	within	visual	line	of	sight	at	all	times.

9. Night	operations	will	not	be	conducted.

10. PIC	will	file	a	NOTAM	providing	GPS	coordinates,	radius/altitude,

date/time, and	contact	information for	each	operation.

11. PIC	and	VO	will	remain	within	talking	distance.

12. PIC	and	VO	will	be	clearly	identified	by	wearing	respective	high	visibility	

vests.

13. The	UV	will	NOT be	operated	near	disaster	or	emergency	areas/scenes

or	in	a	manner	to	interfere	with	such	operations.

Due	to	our	close	proximity	to	the	Washington	DC	Metro	area	and	the	DC	Special	

Flight	Rules	Area	(SFRA)	and	Flight	Restricted	Zone	(FRZ)	the	following	operating	

restrictions	will	be	made:

1. Absolutely	no	flight	in	or	within	2	miles	of	the	border	of	the	DC	FRZ.

2. Only	commercially	rated	pilot	will	act	as	PIC	in	SFRA.

3. All	crewmembers will	take	the	FAA	special	awareness	training	regarding	

the	DC	SFRA	at	faasafety.gov.

4. Flights	will	be	restricted	to	less	than	100	feet	AGL	and	less	than	30kts.

5. Appropriate	authorities	and sector	controlling	agency	will	be	notified	at	

least	24hrs	prior	to	operation.

6. 121.5	will	be	monitored	(listen	only)	at	all	times	by	PIC	and	VO.
KZ	Aerial	Photography requests for	exemption	from the	following	regulations:

14	CFR	Part	21	

14	CFR	91.203	

14	CFR	45.23,	45.29	

14	CFR	91.9	

14	CFR	61.113(a)	&	(b),	61.133(a)	

14	CFR	91.109,	91.119	

14	CFR	91.121,	91.151	

14	CFR	Subpart	E	(91.401-91.417)	FAA	Policy	8900.227	Paragraph	16(c)(4)	and	

Paragraph	16(e)(1)

To	operate	within	the	DC	SFRA,	KZ	Aerial	Photography also	seeks	exemption	from:

14	CFR	93.339

Point	of	contact	for	KZ	Aerial	Photography is:

KZ	Aerial	Photography	

12505	Spring	Drive

Manassas,	VA	20112

(413)	22-9423

kevin.zawistowski@gmail.com

KZ	Aerial	Photography is	committed	to	safety	and	respect	for	privacy.	We	are	

open	and	willing	to	make	necessary	changes	to	maintain	this	commitment.	We	look	

forward	to	working	with	the	FAA	to	achieve	our	business	goals.

Respectfully,

Kevin	M	Zawistowski

Owner,	KZ	Aerial	Photography

Primary	PIC
Appendices:

A. Risk	Mitigation

B. Checklists

C. Flight	Log

D. Pilot	in	Command/	Owner	Background

E. DJI	Manuals (Due	To	file	size	requirements,	Appendix	E	is	not	included	in	this	

file	and	can	be	found	at	http://www.dji.com/product/inspire-1/download)

I. DJI	Safe	Operation	Guidelines

II. DJI	Inspire Owners	Manual

III. DJI	Inspire	Maintenance	Manual
Appendix	A:

Risk	Mitigation Procedures:

Pilot	in	Command	Responsibilities:

1. No	later	than	48	hours	in	advance,	PIC	complete	risk	mitigation	worksheet.

2. PIC	will	brief	crew	on	anticipated	risks	from	risk	mitigation	worksheet	and	

ensure	all	crewmembers	are	aware	of	mitigation	techniques	and	appropriate	

emergency	procedures.

3. Ensure	all	training/certifications	and	medical	requirements	are	current

Visual	Observer	Responsibilities:

1. Review	risk	mitigation	worksheet	completed	by	PIC.

2. Ensure	crew	briefing	takes	place.

Risk	Mitigation	Worksheet:
Appendix	B:

DJI	INSPIRE	CHECKLIST

NOTE:	IF	ANY	CHECK	IS	A	NO-GO,	DO	NOT	FLY	

UNTIL	REMEDIATED.

NOTE:	ALL	COMMANDS	WILL	BE	READ	BY	VO	AND	

CONFIRMED	BY	PIC.

NOTE:	OPERATIONS	BINDER	CONTAINING	DJI	

USER,	MAINTENANCE,	AND SAFETY	MANUALS,	

CHECKLISTS	AND	LOGBOOK WILL	BE	READILY	

AVAILABLE	DURING	ALL OPERATIONS.

BEFORE	DEPARTING	FOR SITE	CHECK

1.___ Ensure	local	authorities/	property	owners	are	notified

2.___ File	NOTAM	if	necessary

3.___ Aircraft	(AC)	and	Remote	Controller	(RC)	batteries	fully	

charged

4.___ Tablet	fully	charged

5.___ Portable	Radio	for	communicating	with	manned	AC	fully	

charged

6.___ Ensure	SD	card	has	free	space	and	is	inserted	into	the	camera

7.___ Ensure	Firmware	is	updated	on	AC	and	RC(s)

8.___ Cache	location	maps	into	all	DJI	Pilot	app	devices

9.___ Program	local	ATC	frequency	into	portable	radio (always	

monitor	guard	on	121.5)

10.___ Check	for	NOTAMs	and	Temporary	Flight	Restrictions	

11.___ Check	weather	at aviationweather.gov	or	1800	WX	BRIEF
SITE	SURVEY

12.___ Check	flying	area	free	of	overhead	obstructions

13.___ Wires,	low	flying	AC,	trees,	tall	buildings

14.___ Antennas	that	may	interfere	with	compass	and	GPS	reception

15.___ Winds	under	20	kts	(23	MPH	or	10	meters	per	second)

16.___ Clouds	above	500’	(152M)

17.___ Visibility	for	1	statute	mile

18.___ Confirm	flight	plan	with	camera	operator	and	visual	observer

19.___ Notify	bystanders	of	operation
PRE-FLIGHT	CHECKS

1.___ Observer	and	Operator	high	visibility	reflective	vests	on	and	

clearly	visible

2.___ All	cables	secure	and	free	of	obstruction

3.___ Optical	Flow/Acoustic	altimeter	sensor	free	of	debris	or	

obstruction

4.___ Check	battery	compartment	free	of	damage,	debris	or	FOD

5.___ Main	fuselage	free	of	obvious	damage,	debris	or	FOD

6.___ Landing	gear	free	of	damage	debris	or	FOD

7.___ Check	motors	1-4:

a. Inspect	Boom	for	damage,	debris	or	FOD

b. Inspect	motor	mount,	ensuring	motor	and	fairings	are	

securely	attached	and	free	of	damage	debris	or	FOD

c. Inspect	motor,	ensure	coils	and	casing	are	free	of	damage	

debris	or	FOD

d. Ensure	motor	shaft	is	free	of	obvious	deformity

e. Verify	motor	spins	freely	(magnetic	resistance	is	normal	from	

residual	charge	in	A/C	capacitors)

f. Inspect	propeller	for	obvious	damage/deformity

g. Verify	propeller	is	securely	attached	to	motor	shaft

8.___ Desired	ND	filter	attached	to	camera

9.___ Camera	locked	in	place

10.___ Verify	Lens	clear	of	debris	or	obstruction

11.___ Gimbal	motor	free	of	damage	debris	or	FOB

12.___ SD	card	in	camera

13.___ Insert	battery	and	check	for	proper	seating
TX/RX	COMMUNICATIONS CHECKS

14.___ Antennas	oriented	Properly	and	free	of	obstruction

15.___ Switch	to	P-GPS	mode

16.___ Landing	gear	switch	oriented	down

17.___ Check	battery	level	of	TX	for	minimum	75%

DJI	PILOT	APP	CHECK S

18.___ Maximum	Flight	altitude	set	to	400	Feet	AGL

19.___ Failsafe	Mode,	Set	for	10M	Clearance	above	lowest	obstacle	in	

flight	plan

20.___ RC	Signal	Lost	set	to	Return-to-Home

21.___ Check	Sensors

22.___ Gyroscope	between	“-1.0	to	+1.0”

23.___ Acceleration	between	“-1.0	to	+1.0”

24.___ Compass	MOD	between	“1400	- 1599”

25.___ Check	IMU

26.___ Image	Transmission	Channel	set

27.___ Watch	channels	for	30	seconds	to	ensure	selected	channel	is	

indeed	stable

28.___ Battery	Cells	all	4.28V	or	greater

29.___ At	least	98%	battery

30.___ Ensure	no	greater	than	.2V	between	battery	cells

31.___ Adjust	Gimbal	Roll	to	make	level

32.___ Ensure	enough	Satellites	are	locked	(recommend	16)

33.___ Set	Camera	Orientation	mode

34.___ Turn	all	mobile	devices	to	airplane	mode

35.___ Face	AC	into	the	wind

36.___ Check	heading	of	Aircraft	

37.___ Start	Video	recording
38.___ Start	Propellers	using	a	Combined	Stick	Command	(CSC)

39.___ Ensure	blue	dot	representing	RC	is	accurately	located	on	map

40.___ Ensure	home	point	is	accurately	set	on	map

41.___ Ensure	elevation	reads	0	(zero)

****CONDUCT	AIRCREW	BRIEFING****
BEFORE	TAKE-OFF	CHECK

1.___ Observer	and	Operator	visible	to	bystanders

2.___ Verbally	confirm	visual	observer	is	in	place	and	ready	to	

observe

a. PIC	“Ready	to	observe?”		VO	“Observing”

3.___ Communications	Systems	Operational

4.___ Aircraft	Systems	Operational

5.___ Landing	gear	down

6.___ Lighting	On

7.___ Verify	take	off	direction	free	of	hazards	and	aircraft	is	into	the	

wind

8.___ Verbally	confirm	take	off	VO	“Take	off	when	ready”,	PIC	

“Airborne”

AFTER	TAKE-OFF	CHECKS

1.___ At	a	5	foot	hover,	verify	the	following

a. Check	flight	controls	correspond	to	proper	aircraft	response

b. Verify	Flight	instruments	indicating	normal

c. Verify	camera	feed	operating	normally

2.___ Gear	up

3.___ Commence	Flight

BEFORE	LANDING	CHECKS

1.___ Gear	down

2.___ Landing	Site	free	of	obstacles	and	obstructions

3.___ Orient	aircraft	into	wind
AFTER	LANDING	CHECKS

1.___ Disarm	aircraft	prior	to	approaching

2.___ Remove	battery

3.___ Turn	off	transmitter

4.___ Notify	appropriate	authorities	of	end	of	flight	(if	final	flight	of	

the	day)

5.___ Conduct	flight	debriefing
Appendix	C:

Flight	Log:

Pilot	in	Command	Responsibilities:

1. Check	logbook	prior	to	flight.

2. Ensure	logbook	is	filled	out	after	each	flight.

Visual	Observer	Responsibilities:

1. Verify	logbook	is	filled	out	correctly	after	flight.

KZ	Aerial	Photography Logbook:
Appendix D

Pilot	in	Command/Owner Background

The	owner	and	primary	pilot	in	command	(PIC)	of	KZ	Aerial	Photography is	

CW2(RET)	Kevin	Zawistowski.	

Mr.	Zawistowski	began	his	career	in	the	US	Army	and	experience	with	UAS	as	

an	Intelligence	Analyst	and	was	medically	retired	from	the	US	Army	as	a	UH60	Blackhawk	Helicopter	Pilot.

He	holds	a	commercial	rotorcraft	certificate	(3634080)	with	instrument	

helicopter	rating	and	a	Sikorsky	S70	type	rating.

His	experience	includes	680	rotary	wing	hours	in	the	UH-60M	and	UH-60A/L	

helicopters with	over	500	hours	in	combat.	Nearly	all	combat	hours	were	

flown	in	close	proximity	with	unmanned	aerial	systems,	ranging	from	the	

RQ-11	Raven	small	UAS	(sUAS) to	the	MQ-9	Reaper.	

While stationed	with	2nd Assault	Helicopter	Battalion	at	Fort	Drum,	he	

worked	closely	with	the	FAA	and	Department	of	the	Army	on the integration	

of	UAS	into	national	airspace	by	organizing	helicopter	chase	aircraft	for	

testing	of	the	RQ-7	Shadow	within	R5201.

Mr.	Zawistowski’s	qualifications	and	experience	give	him	a	unique	

perspective	on	sUAS	operations,	specifically	the	importance	of	airspace	

deconfliction.	This	experience	also	allows	him	to	better	understand	the	

necessity	for	safe	operations	and	the	gravity	of	the	consequences	for	

operating	in	an	unsafe	or	unauthorized	manor.	

For	more	information	on	our	pilots	or	other	personnel,	please	contact	Kevin	

Zawistowski	at	kevin.zawistowski@gmail.com or	413-822-9423.