alternative to the manned aircraft traditionally utilized to obtain aerial data. By reducing 

the amount of manned aircraft needed to perform aerial acquisitions, an exemption 

allowing the use of an S 1 000+ 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 S 1 000+ UA does not require an airport to takeoff or land. Likewise, a reduction of 

manned aircraft conducting aerial survey 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. 

3. The Public Will Benefit From The Safety And Efficiency Of The 

81000+. 

Conducting aerial acquisitions with the S1000+, instead of manned aircraft, will 

greatly benefit the public by drastically reducing the levels of air and noise pollution 

generated during traditional aerial survey flight operations. By using battery power and 

electric motors, the S 1 000+ 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 S 1 000+ UA, while 

21 
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 S1000+ UA 

(maximum gross take-off weight of approximately 25 pounds, a diameter of 41.1 inches 

and height of20 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 aerial acquisitions (weighing 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 Data Acquisition Operations With The SlOOO+ 

Will Benefit The Economy. 

In addition to being safe and efficient, the S 1 000+ is also an economical 

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

the S 1 000+ will allow United States based companies, like NTI, 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 

S 1 000+ 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. 

22 
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, NTI' s proposed operation of the S 1 000+ will not implicate any privacy 

issues. Specifically, the S 1 000+ will be operated in accordance with all Federal Aviation 

Regulations, including the minimum altitude requirements of 14 C.F .R. § 91.119. Most 

significantly, the S 1 000+ UA will not be operated closer than 500 feet to any person, 

vessel, vehicle, or structure, which is not directly involved in the operation unless: 

(a) Barriers or structures are present that sufficiently protect 

nonparticipating person from the UA and/or debris in the event of an accident. 

The operator must ensure that nonparticipating person remain under such 

protection. If a situation arises where nonparticipating person 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; and 

(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. 

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 NTI Seeks Exemption. 

1. Reasons Why The SlOOO+ Meets The Conditions Of The FAA 

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

23 
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.--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 

rulemaldng required by section 332 of this Act or the guidance required by 

section 334 of this Act. 

(b) Assessment of Unmanned Aircraft Systems.--ln 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.--Jfthe 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, NTI submits that the S 1 000+ can operate safely in the 

NAS pursuant to FMRA Section 333, as demonstrated by: (a) the characteristics of the 

S 1 000+; (b) the pilot certification requirement; and (c) the specific operating 

24 
p

y 

g 

e, we

g

t, speed, and 

operational capability. 

i. Technical Specifications Of The SlOOO+. 

The technical specifications of the S 1 000+ are set forth on page 22 and 23 

of the "S1000_Plus_User_Manual_v1.2_en.pdf," attached hereto as Exhibit A. 

ii. The SlOOO+ Autonomous Flight And Navigation Modes 

Enable The UAS To Remain Within A Defined 

Operational Area. 

A complete description of the autonomous modes and methods of navigation 

of the S 1 000+ is provided in Section 2 "Basic Flying" and Section 4 "Advanced 

Features" of the "A2 _Quick_ Start_ Guide_ v1.22 _en. pdf' attached hereto as Exhibit B. 

iii. The SlOOO+ Is Designed For Automatic Return To 

Launch In The Event Of Loss Of The Control Link Or 

Navigation. 

A complete description of the S1000+'s automatic return to launch function in the 

event of a break in communication or loss of telemetry data is set forth in Section 

3.1 of the "A2_Quick_Start_Guide_v1.22_en.pdf' attached hereto as Exhibit B. 

b. Flight Operations Of The SlOOO+ Are Limited To The Line Of 

Sight Of A Certificated Pilot in Command With A Safety 

Observer. 

NTI will only utilize certificated pilots who possess 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, 

25 
minimum of200 flight cycles and 25 hours of total time as a UAS rotorcraft pilot and at 

least ten hours logged as a UAS pilot with a similar UAS type (single blade or 

multirotor). Prior documented flight experience that was obtained in compliance with 

applicable regulations may satisfy this requirement. Training, proficiency, and 

experience-building flights can also be conducted under this grant of exemption to 

accomplish the required flight cycles and flight time. During training, proficiency, 

and experience-building flights, all persons not essential for flight operations are 

considered nonparticipants, and the PIC must operate the UA. 

c. Flights Of The 81000+ Will Be Conducted Pursuant To 

Specific Operating Limitations. 

In seeking this exemption, NTI proposes to commercially operate the S 1 000+ for 

the special purpose of conducting aerial data capture over areas of the United States, 

pursuant to the following specific operating limitations: 

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

following aircraft described in the operator's manual which is an eight rotor 

aircraft weighing less than 55 pounds: DJI S1000+ Unmanned Aircraft System. 

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 52.14 

knots. 

3) The UA must be operated at an altitude of no more than 500 feet 

above ground level (AGL), as indicated by the procedures specified in the 

operator's manual. All altitudes reported to ATC must be in feet AGL. 

26 
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. 

27 
11) NTI 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) NTI UAS technicians must receive and document training 

referenced in the operator's manual. 

13) Each UAS operated under this exemption must comply with all 

manufacturer System and Safety Bulletins. 

14) NTI maintenance personnel must make a record entry in the UAS 

logbook or equivalent document of the corrective action taken against 

discrepancies discovered between inspections. 

15) The PIC must possess either a sport, recreational, or private pilot 

certificate as well as a third-class 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 C.P.R. § 61.56 in an aircraft in which the PIC is rated 

on his or her pilot certificate. 

16) 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. 

28 
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. 

19) 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. 

20) 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 and land, or be recovered in accordance with the operator's manual. 

21) The PIC must abort the flight in the event ofunpredicted obstacles 

or emergencies in accordance with the operator's manual. 

22) 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. 

23) The operator must obtain an Air Traffic Organization (ATO) issued 

Certificate of Waiver or Authorization (COA) prior to conducting any operations 

under this grant of exemption. This COA will also require the operator to request 

issuance of a Notice to Airman (NOT AM) not more than 72 hours in advance, but 

not less than 48 hours prior to the operation. 

24) 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 practicable. 

25) Before conducting operations, the radio frequency spectrum used 

for operation and control of the UA must comply with the Federal 

Communications Commission (FCC) or other appropriate government oversight 

agency requirements. 

26) 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 

29 
29) 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 Charts (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 § 91.119. 

30) Flight operations must be conducted at least 500 feet from all 

nonparticipating 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§ 91.119(a). 

31) 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. 

32) 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. 

30 
has demonstrated, through the S 1 000+ training and currency requirements, that the PIC is 

able to safely operate the S 1 000+ in a manner consistent with this exemption, including 

evasive and emergency maneuvers and maintaining appropriate distances from people, 

vessels, vehicles and structures. 

Considering NTI' 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 (See Exemption No. 11 062); and the airmanship skills 

necessary to safely operate the S1000+, NTI submits that the additional manned airmanship 

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

necessary for NTI' s specific proposed flight operations. 

The S 1 000+ has been the subject of a previous Grants of Exemption from Section 

61.113(a) and (b). Additionally, 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.ExemptionNos.11062, 11063,11064,11065,11066,11067,11080,11109, 

11110, 11112, 11136, 11138). 

As in Exemption No. 11109, NTI will not allow any PIC to operate the SIOOO+ 

unless that PIC has demonstrated through the S 1 000+ training and currency requirements, that 

the PIC is able to safely operate the S 1 000+ in a manner consistent with this exemption, 

including evasive and emergency maneuvers and maintaining appropriate distances from 

people, vessels, vehicles and structures. 

31 
(single blade or multirotor). Prior documented flight experience that was obtained in 

compliance with applicable regulations may satisfy this requirement. Training, 

proficiency, and experience- building flights can also be conducted under this grant of 

exemption to accomplish the required flight cycles and flight time. During training, 

proficiency, and experience-building flights, all persons not essential for flight operations 

are considered nonparticipants, and the PIC must operate the UA. 

3. Reasons Why An Exemption From The Requirements Of Section 61.315 

Would Not Adversely Affect Safety. 

NTI submits that the equivalent level of safety established by Section 61.315 will be 

maintained because no PIC will be allowed to operate the S 1 000+ unless that PIC 

has demonstrated, through the S 1 000+ training and currency requirements, that the PIC is 

able to safely operate the S 1 000+ in a manner consistent with this exemption, including 

evasive and emergency maneuvers and maintaining appropriate distances from people, 

vessels, vehicles and structures. 

Considering NTI' s proposed area of operations, and the operating limitations set 

forth-above; the parallel nature of sport pilot aeronautical knowledge requirements to those of 

private pilot requirements and commercially certified pilot requirements; and the airmanship 

skills necessary to safely operate the S 1 000+, NTI submits that the additional manned 

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

airmanship skills necessary for NTI' s specific proposed flight operations. 

32 
11112, 11136, 11138). 

NTI will not allow any PIC to operate the S 1 000+ unless that PIC has demonstrated 

through the S 1 000+ training and currency requirements, that the PIC is able to safely operate 

the S 1 000+ in a manner consistent with this exemption, including evasive and emergency 

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

structures. 

Prior to operations conducted for the purpose of aerial data acquisition (or similar 

operations), the PIC must have accumulated and logged, in a manner consistent with 14 CFR 

§ 61.51(b), a minimum of200 flight cycles and 25 hours of total time as a UAS rotorcraft pilot 

and at least ten hours logged as a UAS pilot with a similar UAS type (single blade or 

multirotor). Prior documented flight experience that was obtained in compliance with 

applicable regulations may satisfy this requirement. Training, proficiency, and experiencebuilding flights can also be conducted under this grant of exemption to accomplish the required 

flight cycles and flight time. During training, proficiency, and experience-building flights, all 

persons not essential for flight operations are considered nonparticipants, and the PIC must 

operate the UA. 

33 
the UA's compliance with its operating documents (i.e., the S1000+ Flight Manual), and as 

stated in the conditions and limitations herein. 

The S 1 000+ has been the subject of previous Grants of Exemption from Section 

91.7(a). 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). 

5. 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 S 1 000+ 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 

NTI' s operation of the S 1 000+ UA within visual line of sight, at or below 500 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. The S 1 000+ 

has been the subject of previous Grants of Exemption from Section 91.121. Additionally, 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, 

34 
C.F.R. Section 91.151(b) as a result of (1) the technical specifications of the S1000+; (2) the 

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

operations. Accordingly, NTI will ensure that it can safely operate the battery powered S 1 000+ 

UA during daylight hours, in VFR conditions, for a total flight duration of no more than 20 

minutes, resulting in a landing with five minutes of battery power remaining. 

Here, as in Exemption No. 11109, the technical specifications of the S1000+; 

the limitations on the proposed flight operations; and the location of the proposed operations, 

will ensure that NTI may safely operate the battery powered S1000+ UA during daylight 

hours in VFR conditions for a total duration of not more than 20 minutes, and landing with 

five minutes of battery power remaining. 

Significantly, previous exemptions granted by the FAA concerning Section 

91.151 establish that safety is not adversely affected when the technical characteristics and 

operating limitations of the UAS are considered. Relief has been granted for manned aircraft 

to operate at less than the minimums prescribed in Section 91 .151, including Exemption Nos. 

2689,5745, and 10650. Moreover, the FAA has previously granted relieffrom 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). 

35 
91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) will be met because NTI will use its 

trained technicians to perform maintenance, alterations, or preventive maintenance on the 

unmanned aircraft system using the methods, techniques, and practices prescribed in the 

manufacturer's maintenance manual. Furthermore, NTI will document and maintain all 

maintenance records for the S 1 000+. 

Since the S1000+ will be inspected as prescribed by the manufacturer's maintenance 

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

91.409(a)(l), and 91.409(a)(2). The Flight Manual for the S1000+ sets forth airworthiness 

requirements for the UA, including preflight and post flight inspections. Maintenance 

schedules and check lists are referenced in "Pilot Operating Handbook-S1000.pdf' attached 

hereto as Exhibit C. 

Likewise, the exemption sought will not adversely affect safety because NTI 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 S1000+ details procedures for each component of the UA, including the 

components of the propulsion system, avionics system, and payload system. 

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

established by Sections 91.407, 91.417(a) and 91.417(b), because all maintenance of the 

S 1 000+ will be performed by NTI trained technicians, who will document and maintain 

36 
(a)(2), 91.409(a)(2), and 91.417(a) and (b). 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, 11110, 11112, 11136, 

11138). 

8. The FAA May Prescribe Any Other Conditions For Safe Operation. 

In accordance with Section 333 ofthe FAA Modernization and Reform Act of2012 

(FMRA) and 14 C.P.R. § 21.16 entitled Special Conditions, NTI requests that the FAA 

prescribe special conditions for the intended operation of the S1000+, which contain such 

safety standards that the Administrator finds necessary to establish a level of safety equivalent 

to that established by 14 C.P.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 UA for the limited purpose of conducting 

aerial 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 C.F .R. 

§ 21.16, for operation of the S1000+, since the airworthiness regulations of 14 C.P.R. Part 

21 do not contain adequate or appropriate safety standards, due to the novel or unusual 

37 
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 NTI' s intended operation of the S 1 000+, 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), 61.315 (a), (b) & (c), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(l), 

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

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

From Which NTI Seeks Exemption: 

NEEDMORE TOWERS, INC, seeks exemptionfrom the requirements of 14 CF.R 

Sections 61.113(a)&(b), 61.315 (a), (b), & (c), 91.7(a), 91.121, 91.151(b), 91.405(a), 

91.407(a)(l), 91.409(a)(l) & (a)(2), and 91.41 7(a) & (b). 

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

This exemption will permit NEEDMORE TOWERS, INC, to commercially operate 

an Unmanned Aircraft System (UAS) for the purpose of conducting aerial data 

acquisition over areas of the United States. 

38 
certain UAS may operate safely in the NAS. As such, NTI's request for exemption may 

be granted pursuant to the authority ofFMRA Section 333 and 14 C.P.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, NTI will operate the S 1 000+ 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, Needmore Towers, Inc. seeks an exemption pursuant to 14 C.P.R. 

§ 11.61 and Section 333 ofthe FAA Modernization and Reform Act of2012 (FMRA), 

which will permit safe operation of the DJI Innovations Spreading Wings S 1 000+ Unmanned 

Aircraft commercially, without an airworthiness certificate, for the limited purpose of 

conducting aerial acquisitions over 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, 

by allowing NTI to safely, efficiently, and economically operate the S 1 000+ commercially 

within the NAS. 

39 
& (a)(2), and 91.417(a) & (b), and permit NTI to operate the S1000+ commercially for the 

purpose of conducting aerial data capture. 

Dated: June 8, 2015 

NEEDMORE TOWERS, INC. 

MarkA. Ekse 

Hagen, Wilka & Archer, LLP 

Attorneys for Petitioner 

cc: Eric Taylor 

40