U.S. Department of Transportation, Docket Operations

West Building Ground Floor, Room W12-140

1200 New Jersey Ave., SE

Washington, DC 20590 

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

Aviation Regulations - Straub Surveying, LLC

Dear Sir/Madam,

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

Act), and 14 C.F.R. Part 11, Straub Surveying, LLC (“Straub Surveying”), an Ohio based 

Professional Land Surveying and High Definition 3D Laser Scanning company equipped to 

operate an Unmanned Aircraft System (UAS), hereby applies for an exemption from the 

Federal Aviation Regulations (FARs) listed below to allow operation of a UAS commercially in 

airspace regulated by the Federal Aviation Administration (FAA) so long as such operations 

are conducted with and under the conditions outlined herein or as may be established by the 

FAA as required by Section 333.

Granting this exemption would allow Straub Surveying to enhance its existing 

Professional Land Surveying, Mapping, and 3D Laser Scanning services, through the use of a 

small, lightweight UAS - the DJI Inspire 1 - and cloud-based software, enabling the company 

to collect, process, and analyze high-quality 3D imaging and videos for surveying, mapping, 

and spatial analysis for a variety of construction, commercial, residential, and public uses, 

specifically targeting:

● Aerial land surveying and mapping

● Construction monitoring, planning & inspection

● Volumetric analysis of mining stockpiles

● Digital elevation models (DEMs) 

● Existing conditions documentation

● Aerial photogrammetry and videography 

● Building Information Modeling (BIM)

● Precision agriculture services

● Marketing services

● Increasing public knowledge of UAS and promoting safe UAS operations

Straub Surveying submits that because the UAS will be used in lieu of comparatively 

hazardous operations now conducted with fixed wing and rotary conventional aircraft, the FAA 

can have confidence that the operations will achieve at least an equivalent level or greater of 
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Phone (440) 333-1700 • Info@StraubSurveying.com

safety and benefit the public as a whole. Approval of this exemption would thereby enhance 

safety and fulfill the Secretary of Transportation's (the FAA Administrator's) responsibilities 

under Section 333(c) of the Reform Act to "establish requirements for the safe operation of 

such aircraft systems in the national airspace system."

Straub Surveying is prepared to modify or amend any part of this request to satisfy your 

requirements. Please contact us at any time if you require additional information or 

clarification.

Sincerely, 

___________________________

Michael A. Straub, PS

Straub Surveying, LLC

3580 Eldorado Drive

Rocky River, OH 44116

Tel: (440) 333-1700
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TABLE OF CONTENTS

GLOSSARY OF ABBREVIATIONS............................................................................................. 4

SUMMARY .................................................................................................................................. 5

COMPANY INTRODUCTION AND INTERESTS OF THE PETITIONER ................................... 5

VEHICLE DESCRIPTION & BACKGROUND: DJI Inspire 1 UAS............................................... 6

BASIS FOR PETITION................................................................................................................ 6

INFORMATION TO SUPPORT PETITION, IN ACCORDANCE WITH 14 C.F.R. § 11.81:......... 8

A. NAME AND ADDRESS OF THE PETITIONER. ............................................................................ 8

B. THE SPECIFIC SECTION(S) OF 14 CFR FROM WHICH STRAUB SURVEYING SEEKS 

AN EXEMPTION. ........................................................................................................................... 8

C. THE EXTENT OF RELIEF STRAUB SURVEYING SEEKS, AND THE REASON STRAUB 

SURVEYING SEEKS THE RELIEF.............................................................................................. 11

D. THE REASONS WHY GRANTING STRAUB SURVEYING’S REQUEST WOULD BE IN 

THE PUBLIC INTEREST; THAT IS, HOW IT WOULD BENEFIT THE PUBLIC AS A 

WHOLE ........................................................................................................................................ 14

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 STRAUB 

SURVEYING SEEKS EXEMPTION. ............................................................................................ 16

F. SUMMARY THAT CAN BE PUBLISHED IN THE FEDERAL REGISTER ................................... 26

G. ANY ADDITIONAL INFORMATION, VIEWS, OR ARGUMENTS AVAILABLE TO SUPPORT 

STRAUB SURVEYING’S REQUEST. .......................................................................................... 27

CONCLUSION........................................................................................................................... 27
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GLOSSARY OF ABBREVIATIONS 

AGL Above Ground Level

AOI Area of Interest

ATC Air Traffic Control

ATO Air Traffic Organization

AV Aerial 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 Visual Meteorological Conditions

VTOL Vertical Takeoff and Landing 
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SUMMARY

Straub Surveying, LLC seeks exemption from the requirements of 14 C.F.R § 61.113(a) & (b), 

61.23, 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), to operate an Unmanned Aircraft System (UAS) pursuant to Section 333 of 

the FAA Modernization and Reform Act of 2012 (FMRA). This exemption will permit Straub 

Surveying to pursue its commercial interests in providing services to clients interested aerial 

data capture using a UAS.

COMPANY INTRODUCTION AND INTERESTS OF THE PETITIONER 

As previously mentioned, the objective of Straub Surveying, LLC’s aerial photogrammetry and 

surveying operations is to provide high-quality 3D imaging and videos for surveying, mapping, 

and spatial analysis for a variety of construction, commercial, residential, and public uses, 

specifically targeting:

● Aerial land surveying and mapping

● Construction monitoring, planning & inspection

● Volumetric analysis of mining stockpiles

● Digital elevation models (DEMs) 

● Existing conditions documentation

● Aerial photogrammetry and videography 

● Building Information Modeling (BIM)

● Precision agriculture services

● Marketing services

● Increasing public knowledge of UAS and promoting safe UAS operations

Straub Surveying is a small, Ohio based Land Surveying and 3D Laser Scanning limited 

liability company with over 30 years of professional land surveying and mapping experience. 

The company is one of the few in Ohio to perform High Definition 3D Laser Scanning on 

construction projects. It currently operates four surveying crews, mainly servicing General 

Contractors on construction projects, most of which are repeat customers.

Furthermore, Straub Surveying’s use of the UAS will be performed under the supervision of a 

Professional Land Surveyor whom, by virtue of his or her experience and licensing, technical 

knowledge of GPS, plane geometry, trigonometry and spherical geometry inherently and 

uniquely makes Straub Surveying a particularly well suited entity for the safe and efficient 

commercial use of a UAS.
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VEHICLE DESCRIPTION & BACKGROUND: DJI Inspire 1 UAS

The UAS Straub Surveying seeks an exemption to operate for compensation or hire within the 

NAS is constructed by DJI and referred to as the Inspire 1. The DJI Inspire 1 is a vertical 

takeoff and landing (VTOL) Unmanned Aircraft (UA) with a Ground Control Station (GCS) 

utilizing electronic tablet or smart phone systems. The DJI Inspire 1 has a maximum gross 

weight of approximately 6 pounds 7.5 ounces, while having a length of 17.24 inches, width of 

17.75 inches, height of 11.85 inches, and a maximum speed of approximately 42 knots. The 

DJI Inspire 1 is equipped with four main rotors; driven by Lithium Polymer battery powered 

electric motors.

The Inspire 1 can be operated entirely by a touch-screen, map-based interface. The UAS can 

be operated in both semi and fully autonomous flight modes, with the operator simply clicking 

on a map to create a preplanned flight path for a flight. In addition, the operator can create 

maximum flight ranges and altitudes so the system cannot enter areas deemed unsafe or 

unnecessary to fly over. The UAS has built-in intelligent fault handling which allows the Inspire 

1 to detect a system fault while in the air and automatically fly back to its take-off location and 

land. Faults that can be detected include: loss of communication; loss of GPS lock; and low 

battery levels.

All flight operations are global positioning system (GPS) controlled, making the system easy 

to navigate. At any point if the operator is not explicitly commanding the system to move, the 

system automatically holds its GPS position. Also a flight termination link - to prevent a "fly 

away" or other potentially dangerous situation - is available to the operator.

The DJI Inspire 1 UAS that will be operated by Straub Surveying 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, Straub Surveying, 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, Straub Surveying’s operation of the DJI Inspire 1 UAS 
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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.

Accordingly, Straub Surveying 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.

Straub Surveying submits that the requested relief is proper since an equivalent level of safety 

will be ensured. Straub Surveying 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 UAS operating documents (i.e., the DJI Inspire 1 

User Manual, Maintenance Manual, and Safety Guidelines, attached hereto as Exhibits B, D, 

and E, respectively). Furthermore, Straub Surveying will document and maintain all 

maintenance records for the DJI Inspire 1 UAS using the Straub Surveying UAS Monthly 

Maintenance Log, attached hereto as Exhibit C.

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

and limitations: Pilot in command, is requested by Straub Surveying to the extent necessary to 

allow a Pilot in Command (PIC) holding either an airline transport, commercial, private, 

recreational, or sport pilot certificate, as well as a valid US driver’s license, and who 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 this exemption, 

including evasive and emergency maneuvers and maintaining appropriate distances from 

people, vessels, vehicles and structures.

Straub Surveying seeks relief from Section 91.7(a), entitled Civil aircraft airworthiness,

because the DJI Inspire 1 UA does not require an airworthiness certificate in accordance with 

14 C.F.R. Part 21, Subpart H. As such, Straub Surveying submits that the company 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., the DJI Inspire 

1 User Manual, Maintenance Manual, and Safety Guidelines, attached hereto as Exhibits B, 

D, and E, respectively, as well as Straub Surveying’s UAS Monthly Maintenance Log, 

attached hereto as Exhibit C), and that the aircraft are in a condition for safe flight.

Straub Surveying also seeks an exemption from the requirements of Section 91.121, entitled 

Altimeter Settings, as the DJI Inspire 1 UAS will not have a typical barometric altimeter 

onboard. However, altitude information of the DJI Inspire 1 UAS 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 Straub Surveying’s operation of the DJI Inspire 1 UAS within 
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visual line of sight, at or below 400 feet AGL, will ensure a level of safety equivalent to Section 

91.121.

Additionally, Straub Surveying seeks an exemption from the requirements of Section 

91.151(b), entitled Fuel requirements for flight in VFR conditions. Straub Surveying submits 

that safety will not be affected by operation of the DJI Inspire 1 UAs 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.

INFORMATION TO SUPPORT PETITION, IN ACCORDANCE WITH 14 C.F.R. § 11.81:

A. NAME AND ADDRESS OF THE PETITIONER. 

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

Straub Surveying, LLC

Attn: Michael A. Straub, PS

3580 Eldorado Dr.

Rocky River, OH 44116

Tel: (440) 333-1700

Email: Info@StraubSurveying.com

B. THE SPECIFIC SECTION(S) OF 14 CFR FROM WHICH STRAUB SURVEYING SEEKS 

AN EXEMPTION.

1. Straub Surveying Seeks Exemption From The Requirements Of Section 61.113(a) 

And (b).

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

subsections (a) and (b) prescribe the following, in relevant part:

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

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

that person, for compensation or hire, act as 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. Straub Surveying Seeks Exemption From The Requirements Of Section 61.23.

Section 61.23, entitled Medical certificates; Requirement and duration, prescribes the 

following, in relevant part: 
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(a) Operations requiring a medical certificate. Except as provided in paragraphs (b) 

and (c) of this section, a person—

(1) Must hold a first-class medical certificate:

(i) When exercising the pilot-in-command privileges of an airline transport pilot 

certificate;

(ii) When exercising the second-in-command privileges of an airline transport 

pilot certificate in a flag or supplemental operation in part 121 of this chapter 

that requires three or more pilots; or

(iii) When serving as a required pilot flight crew member in an operation 

conducted under part 121 of this chapter if the pilot has reached his or her 

60th birthday.

(2) Must hold at least a second class medical certificate when exercising:

(i) Second-in-command privileges of an airline transport pilot certificate in part 

121 of this chapter (other than operations specified in paragraph (a)(1)(ii) of 

this section); or

(ii) Privileges of a commercial pilot certificate; 

3. Straub Surveying Seeks Exemption From The Requirements Of Section 91.7(a).

Section 91.7, entitled Civil aircraft airworthiness, subsection (a), states the following:

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

4. Straub Surveying 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.

5. Straub Surveying Seeks Exemption From The Requirements Of Section 

91.151(b).

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

states the following:
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(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.

6. Straub Surveying Seeks Exemption From The Requirement Of Section 91.405(a).

Section 91.405, entitled Maintenance required, subsection (a), states the following: 

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[.]

7. Straub Surveying 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) It has been approved for return to service by a person authorized under §43.7 

of this chapter[.]

8. Straub Surveying Seeks Exemption From The Requirements Of Sections 

91.409(a)(1) And 91.409(a)(2).

Section 91.409, entitled Inspections, 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 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 § 43.7 of this chapter; 

or

(2) An inspection for the issuance of an airworthiness certificate in accordance 

with part 21 of this chapter.

9. Straub Surveying Seeks Exemption From The Requirements Of Sections 

91.417(a) And 91.417(b).

Section 91.417, entitled Maintenance records, subsections (a) and (b), states the 

following:

(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:
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(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 

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 STRAUB SURVEYING SEEKS, AND THE REASON STRAUB 

SURVEYING SEEKS THE RELIEF. 

1. Extent Of Relief Straub Surveying Seeks And The Reason Straub Surveying 

Seeks Relief From Section 61.113(a) And (b).

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 either an 

airline transport, commercial, private, recreational, or sport pilot certificate, as well as a 
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valid US driver’s license, 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, Straub Surveying submits that an equivalent level of 

safety will be maintained because no PIC will be allowed to operate the DJI 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, Straub Surveying 

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 Straub Surveying’s business; and (2) will 

not carry passengers or property for compensation or hire.

2. Extent Of Relief Straub Surveying Seeks And The Reason Straub Surveying 

Seeks Relief From Section 61.23.

Relief from portions of Section 61.23, entitled Medical certificates; Requirement and 

duration, is requested to the extent necessary to allow a designated PIC to have a valid 

US driver’s license issued by the state in lieu of an airman medical certificate.

Given the size, weight, structure, limited flight area and the safety features integrated 

into the DJI Inspire 1 UAS, Straub Surveying believes that an Equivalent Level of 

Safety can be reached if the PIC has a valid US driver's license, as it shows the ability 

to follow safe operating instructions for a man-controlled vehicle.

3. Extent Of Relief Straub Surveying Seeks And The Reason Straub Surveying 

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 Straub Surveying to determine that the DJI Inspire 1 UAS are 

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

with the DJI Inspire 1 operating documents.

Straub Surveying 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, Straub Surveying will ensure that the DJI Inspire 1 UAS are in airworthy 

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

1 User Manual, Maintenance Manual, and Safety Guidelines, attached hereto as 

Exhibits B, D, and E, respectively, as well as Straub Surveying’s UAS Monthly 
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Maintenance Log, attached hereto as Exhibit C), prior to every flight, and further, 

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

limitations below.

4. Extent Of Relief Straub Surveying Seeks And The Reason Straub Surveying 

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), Straub Surveying seeks the 

requested relief because the DJI Inspire 1 UAS’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 level of safety will 

be maintained since the DJI Inspire 1 UAS is 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.

5. Extent Of Relief Straub Surveying Seeks And The Reason Straub Surveying 

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 

UAs 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. Straub 

Surveying seeks the requested relief because without an exemption from Section 

91.151(b), the flight time duration of the battery powered DJI Inspire 1 UAs will severely 

constrain the practicality of any aerial video or still photo flight operations that Straub 

Surveying proposes to conduct pursuant to this Petition.

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

the DJI Inspire 1 operating documents, and Straub Surveying’s proposed operating 

limitations, ensure that Straub Surveying will safely operate the battery powered DJI 

Inspire 1 UAs 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.
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6. Extent Of Relief Straub Surveying Seeks And The Reason Straub Surveying 

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, Straub Surveying requests relief from 

these Sections because the DJI Inspire 1 UAS do 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, Straub 

Surveying 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 DJI Inspire 1 User Manual, 

Maintenance Manual, and Safety Guidelines, attached hereto as Exhibits B, D, and E, 

respectively). Furthermore, Straub Surveying will document and maintain all 

maintenance records for the DJI Inspire 1 UAS using the company’s UAS Monthly 

Maintenance Log, attached hereto as Exhibit C.

D. THE REASONS WHY GRANTING STRAUB SURVEYING’S REQUEST WOULD BE IN 

THE PUBLIC INTEREST; THAT IS, HOW IT WOULD BENEFIT THE PUBLIC AS A 

WHOLE

By granting this request for exemption and allowing Straub Surveying’s use of the DJI 

Inspire 1 UAS, the public will experience decreased congestion of the NAS as well as 

significant environmental, public safety, and economic benefits, all of which are in the 

public interest. In addition, the benefits of Straub Surveying’s proposed operation of the 

DJI Inspire 1 UAS will be realized without implicating any privacy issues.

1. The Public Will Benefit From Decreased Congestion Of The NAS.

The DJI Inspire 1 UAS is battery powered and serves 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 UAS does not require an airport to takeoff or land. Likewise, a 

reduction of manned aircraft conducting aerial video and photography missions would 

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

takeoff, departure, arrival, and landing phases of flight operations.

2. The Public Will Benefit From The Safety And Efficiency Of The DJI Inspire 1 UAS.
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Conducting aerial acquisitions with the DJI 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 typically utilized for aerial video 

and photography, while burning approximately 20-30 gallons per hour of leaded 

aviation fuel. The DJI Inspire 1 UAs, while reducing the carbon footprint of aerial 

acquisitions, also eliminates noise pollution, as the UAS is propelled by battery 

powered electric motors, rather than an internal combustion engine. 

In addition to environmental benefits, using the DJI Inspire 1 UAS will significantly 

reduce or completely eliminate the substantial risk to life and property in the air and on 

the ground, which is usually associated with traditional manned aircraft flight 

operations. Aside from the lack of flight crew members located onboard the aircraft, 

the DJI Inspire 1 UAS (weighing approximately 6 pounds 7.5 ounces while having a 

length of 17.24 inches, width of 17.75 inches, height of 11.85 inches), 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).

As far as efficiency, using the DJI Inspire 1 UAS, as opposed to manned aircrafts, will 

provide significant efficiency enhancements that will benefit the public as a whole. For 

example, a mission does not need a long preparation time, long deployment 

constraints, or long waiting time for perfect weather conditions. Initial results are 

accessible directly on-site, which is impossible with images provided by satellites or 

manned aircrafts. This will ultimately increase the speed of projects, as land surveying 

is only one of the first steps of many involved with completing a construction project. 

When the land surveying process can be completed quicker, the rest of the project can 

proceed as planned, companies can reach deadlines with no delays, and the public 

benefits. 

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

Will Benefit The Economy.

In addition to being safe and efficient, the DJI Inspire 1 UAS is 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 

Straub Surveying, to remain competitive and contribute to growth of the U.S. economy.

Specifically, with the rising cost of aviation fuel and the Environmental Protection 

Agency (EPA) regulatory actions phasing out leaded aviation fuels, U.S. owned and 

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

competitive. Operating the battery powered DJI Inspire 1 UAS is one such technology 

that not only allows companies greater operational flexibility compared to manned 
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aircraft, but provides such flexibility without the high operational cost of a traditional 

manned aircraft.

By operating the DJI Inspire 1 UAS, companies such as Straub Surveying 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, Straub Surveying’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 DJI Inspire 1 User Manual, 

Maintenance Manual, and Safety Guidelines), which require 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.

In addition, Straub Surveying submits that all flights will occur over private or controlled 

access property with the property owner's prior consent and knowledge. Images taken 

will be of individuals who have also consented to being filmed or otherwise have 

agreed to be in the area where aerial photography will take place.

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 

STRAUB SURVEYING SEEKS EXEMPTION.

1. Reasons Why The DJI Inspire 1 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, Straub Surveying’s operation of the DJI Inspire 

1 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 
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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.--Notwithstanding 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 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, Straub Surveying submits that the DJI 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 DJI Inspire 1 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.

i. Technical Specifications Of The DJI Inspire 1 UAS.

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

DJI Inspire 1 Specifications and Data Sheet, attached hereto as Exhibit A.

ii. The DJI Inspire 1 UAS Autonomous Flight And Navigation Modes 

Enable 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 in the DJI Inspire 

1 User Manual, attached hereto as Exhibit B.
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iii. The DJI Inspire 1 UAS Is Designed For Automatic Return To Home 

Point Or Hover In The Event Of Loss Of The Control Link Or 

Navigation.

If the Control Link is lost, the DJI Inspire 1 the UAS will remain stationary, 

in flight, for 3 seconds or more. If, after 3 seconds, the DJI Inspire 1 UAS 

does not reacquire control link data from the GCS, the UA will assume 

that the Control Link is lost and the UA will return to the home position 

(i.e., failsafe mode) via GPS, and will descend to the takeoff position and 

shutdown. A complete description of the Failsafe Functions of the DJI 

Inspire 1 can be found at pages 13 through 15 of the DJI Inspire 1 User 

Manual, attached hereto as Exhibit B, as well as the DJI Inspire 1 Safety 

Guidelines, attached hereto as Exhibit E.

iv. The DJI Inspire 1 GCS And Its Operation.

A complete description of the operation and specifications of the DJI 

Inspire 1 GCS and flight control software can be located in the DJI Inspire 

1 User Manual. The DJI Inspire 1 User Manual is attached hereto as 

Exhibit B.

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

Certificated Pilot in Command With A Safety Observer.

Straub Surveying will utilize a PIC holding either an airline transport, 

commercial, private, recreational, or sport pilot certificate, as well as a valid US 

driver’s license, and who has met certain flight-hour and currency requirements, 

to conduct the proposed UAS flight operations. Additionally, a visual observer 

(VO) will assist the PIC during flight time. The UAS will be operated within the 

visual line of sight (VLOS) of the PIC and VO at all times, though the VO may be 

used to satisfy the VLOS requirement as long as the PIC always maintains 

VLOS capability.

c. Flights Of DJI Inspire 1 UAS Will Be Conducted Pursuant To Specific 

Operating Limitations.

In seeking this exemption, Straub Surveying proposes to commercially operate 

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:

1. Operations authorized by this grant of exemption are limited to the DJI 

Inspire 1 when weighing less than 55 pounds including payload. 

Proposed operations of any other aircraft will require a new petition or a 

petition to amend this exemption.

2. Operations for the purpose of closed-set motion picture and television 

filming are not permitted.

3. The UA may not be operated at a speed exceeding 87 knots (100 miles 

per hour). The exemption holder may use either groundspeed or 

calibrated airspeed to determine compliance with the 87 knot speed 

restriction. In no case will the UA be operated at airspeeds greater than 
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the maximum UA operating airspeed recommended by the aircraft 

manufacturer.

4. The UA must be operated at an altitude of no more than 400 feet above 

ground level (AGL). Altitude must be reported in feet AGL.

5. 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 FAAissued airman medical certificate or U.S. driver’s license.

6. All operations must utilize a visual observer (VO). The UA must be 

operated within the visual line of sight (VLOS) of the PIC and VO at all 

times. The VO may be used to satisfy the VLOS requirement as long as 

the PIC always maintains VLOS capability. The VO and PIC must be able 

to communicate verbally at all times; electronic messaging or texting is 

not permitted during flight operations. The PIC must be designated before 

the flight and cannot transfer his or her designation for the duration of the 

flight. The PIC must ensure that the VO can perform the duties required 

of the VO.

7. This exemption and all documents needed to operate the UAS and 

conduct its operations in accordance with the conditions and limitations 

stated in this grant of exemption, are hereinafter referred to as the 

operating documents. The operating documents must be accessible 

during UAS operations 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 operating documents, 

the conditions and limitations herein 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 or any law enforcement official upon request. The operator 

must also present updated and revised documents if it petitions for 

extension or amendment to this grant of exemption. 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 an 

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.

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 prior to conducting 

further operations under this exemption. Functional test flights may only 

be conducted by a PIC with a VO and must remain at least 500 feet from 

other people. The functional test flight must be conducted in such a 

manner so as to not pose an undue hazard to persons and property.

9. The operator is responsible for maintaining and inspecting the UAS to 

ensure that it is in a condition for safe operation.
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10.Prior to each flight, the PIC must conduct a pre-flight inspection and 

determine the UAS is in a condition for safe flight. The pre-flight 

inspection must account for all potential discrepancies, e.g., inoperable 

components, items, or equipment. 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.

11.The operator must follow the UAS manufacturer’s maintenance, overhaul, 

replacement, inspection, and life limit requirements for the aircraft and 

aircraft components.

12.Each UAS operated under this exemption must comply with all 

manufacturer safety bulletins.

13.Under this grant of exemption, a PIC must hold either an airline transport, 

commercial, private, recreational, or sport pilot certificate. The PIC must 

also hold a current FAA airman medical certificate or a valid U.S. driver’s 

license issued by a state, the District of Columbia, Puerto Rico, a territory, 

a possession, or the Federal government. The PIC must also meet the 

flight review requirements specified in 14 CFR § 61.56 in an aircraft in 

which the PIC is rated on his or her pilot certificate.

14.The operator may not permit any PIC to operate unless the PIC 

demonstrates the ability 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 persons, vessels, vehicles and structures. PIC 

qualification flight hours and currency must be logged in a manner 

consistent with 14 CFR § 61.51(b). Flights for the purposes of training the 

operator’s PICs and VOs (training, proficiency, and experience-building) 

and determining the PIC’s ability to safely operate the UAS in a manner 

consistent with how the UAS will be operated under this exemption are 

permitted under the terms of this 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 CFR § 91.119.

15.UAS operations may not be conducted during night, as defined in 14 CFR 

§ 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 an airport reference 

point (ARP) as denoted in the current FAA Airport/Facility Directory (AFD) 

or for airports not denoted with an ARP, the center of the airport symbol 

as denoted on the current FAA-published aeronautical chart, unless a 

letter of agreement with that airport’s management is obtained or 

otherwise permitted by a COA issued to the exemption holder. The letter 

of agreement with the airport management must be made available to the 

Administrator or any law enforcement official upon request.
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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 pre-determined location within the private or controlled-access 

property.

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

emergencies.

20.The PIC is prohibited from beginning a flight unless (considering wind and 

forecast weather conditions) there is enough available power for the UA 

to conduct the intended operation and to operate after that for at least five 

minutes or with the reserve power recommended by the manufacturer if 

greater.

21.Air Traffic Organization (ATO) Certificate of Waiver or Authorization 

(COA). All operations shall be conducted in accordance with an ATOissued COA. The exemption holder may apply for a new or amended 

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

the terms of the attached COA.

22.All aircraft operated in accordance with this exemption must be identified 

by serial number, registered in accordance with 14 CFR part 47, and

have identification (N−Number) markings in accordance with 14 CFR part 

45, Subpart C. Markings must be as large as practicable.

23.Documents used by the operator to ensure the safe operation and flight 

of the UAS and any documents required under 14 CFR §§ 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 give way to all 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.All Flight operations must be conducted at least 500 feet from all 

nonparticipating persons, vessels, vehicles, and structures unless:

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 in a 

manner ensuring the safety of nonparticipating persons;

b. The owner/controller of any vessels, vehicles or structures has 

granted permission for operating closer to those objects and the 

PIC has made a safety assessment of the risk of operating closer 

to those objects and determined that it does not present an undue 

hazard.
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The PIC, VO, operator trainees or essential persons are not considered 

nonparticipating persons under this exemption.

27.All operations shall be conducted over private or controlled-access 

property with permission from the property owner/controller or authorized 

representative. Permission from property owner/controller or authorized 

representative will be obtained for each flight to be conducted.

28.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.

Straub Surveying 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 Straub Surveying’s proposed area of operations and the operating 

limitations set forth, as well as the airmanship skills necessary to safely operate the DJI 

Inspire 1 UAS, Straub Surveying submits that the additional manned airmanship 

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

skills necessary for Straub Surveying’s specific proposed flight operations. In addition, 

because the UAS will not carry a pilot or passengers, the proposed operations can 

achieve the equivalent level of safety of current operations by requiring the pilot 

operating the aircraft to have completed UAS manufacturers flight training before flying 

a UAS. Unlike a conventional aircraft that carries the pilot and passengers, the UAS is 

remotely controlled with no living thing or cargo on board. The area of operation is 

controlled and restricted, and all flights are planned and coordinated in advance as set 

forth in the DJI Inspire 1 User Manual, Maintenance Manual, and Safety Guidelines. 

The risks associated with the operation of the small UAS are so diminished from the 

level of risk associated with commercial operations contemplated by Part 61 when 

drafted, that allowing operations of the UAS as requested exceeds the present level of 

safety achieved by 14 CFR 61.113(a) and (b). 

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).
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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 Straub Surveying’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 PIC 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 exemption. 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. In addition 

to the hour requirements, the PIC 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, Straub Surveying 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 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.

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, Straub Surveying will ensure that the DJI Inspire 1 UAS is 

in an airworthy condition compliant with its operating documents and as stated in the 

conditions and limitations herein.
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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 UAS 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 Straub Surveying’s operation of the DJI Inspire 1 UAS 

within visual line of sight, at or below 400 feet AGL, will ensure a level of safety 

equivalent to Section 91.121. The altitude information will be generated by GPS 

equipment installed onboard the aircraft. Prior to each flight, a zero altitude initiation 

point is automatically established by the 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).

5. Reasons Why An Exemption From The 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 

1 UAS; (2) the limitations on the proposed flight operations; and (3) the location of the 

proposed flight operations. Accordingly, Straub Surveying will ensure that it will safely 

operate the battery powered DJI Inspire 1 UAS 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 UAs 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 
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operate at less than the minimums prescribed in Section 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) Would Not Adversely Affect 

Safety.

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

alterations, and preventive upkeep using the methods, techniques, and practices 

prescribed in the operating documents, specifically the DJI Inspire 1 User Manual,

Maintenance Manual, and Safety Guidelines (attached hereto as Exhibits B, D, and E, 

respectively).

Furthermore, Straub Surveying will document and maintain all maintenance records for 

the DJI Inspire 1 UAS using Straub Surveying’s UAS Monthly Maintenance Log, 

attached hereto as Exhibit C.

An equivalent level of safety will be achieved because these UASs are very limited in 

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

periods of time. If mechanical issues arise, the UAS can land immediately and will be 

operating from no higher than 400 feet AGL. As provided in the DJI Inspire 1 User 

Manual, Maintenance Manual, and Safety Guidelines (attached hereto as Exhibits B, D, 

and E, respectively), the operator will ensure that the UAS is in working order prior to 

initiating flight, perform required maintenance and keep a log of any maintenance 

performed. 

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. The FAA has previously granted relief 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).

In consideration of Straub Surveying’s proposed operating limitations, the operating 

documents, and the technical aspects of the DJI Inspire 1 UAS, Straub Surveying 

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). 
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3580 Eldorado Drive • Rocky River, Ohio 44116

Phone (440) 333-1700 • Info@StraubSurveying.com

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 Special Conditions, Straub Surveying 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 Straub Surveying 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. SUMMARY THAT CAN BE PUBLISHED IN THE FEDERAL REGISTER
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3580 Eldorado Drive • Rocky River, Ohio 44116

Phone (440) 333-1700 • Info@StraubSurveying.com

The Rules From Which Straub Surveying Seeks Exemption:

Straub Surveying, LLC seeks exemption from the requirements of 14 C.F.R Sections 

61.113(a)&(b), 61.23 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 Straub Surveying Seeks:

This exemption will permit Straub Surveying, LLC to commercially operate the DJI 

Inspire 1 UAS Unmanned Aircraft System (UAS) for the purpose of conducting 

precision aerial surveying services for a variety of construction, commercial, residential, 

and public uses. 

G. ANY ADDITIONAL INFORMATION, VIEWS, OR ARGUMENTS AVAILABLE TO 

SUPPORT STRAUB SURVEYING’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, Straub Surveying’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, Straub Surveying 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, Straub Surveying seeks an exemption pursuant to 14 C.F.R. §11.61 and 

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

operation of the DJI Inspire 1 UAS commercially, without an airworthiness certificate, for the

limited purpose of conducting precision aerial surveying services over small, defined 

operational areas of 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.

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

Modernization and Reform Act of 2012, Section 333, Straub Surveying respectfully requests 

that the Administrator grant this Petition for an exemption from the requirements of 14 C.F.R 

Sections 61.113(a) & (b), 61.23, 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 Straub Surveying to operate the DJI 
Page 28 of 28

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3580 Eldorado Drive • Rocky River, Ohio 44116

Phone (440) 333-1700 • Info@StraubSurveying.com

Inspire 1 UAS commercially for the purpose of conducting precision aerial surveys, for a 

variety of construction, commercial, residential, and public uses.

Dated: November 23, 2015

Respectfully submitted, 

___________________________

Michael A. Straub, PS

Straub Surveying, LLC

3580 Eldorado Drive

Rocky River, OH 44116

Tel: (440) 333-1700

Info@StraubSurveying.com

Appendices:

EXHIBIT A – DJI Inspire 1 Specifications Data Sheet

EXHIBIT B – DJI Inspire 1 User Manual

EXHIBIT C – Straub Surveying UAS Monthly Maintenance Log

EXHIBIT D – DJI Inspire 1 Maintenance Manual, 

EXHIBIT E – DJI Inspire 1 Safety Guidelines