August 26, 2015

U. S. Department of Transportation, Docket Operations

West Building Ground Floor, Room W12-140

1200 New Jersey Ave.,

Washington, DC 20590

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

Regulations

Dear Sir or Madam:

Pursuant to the Section 333 of the FAA Modernization and Reform Act of 2012 (the "Reform Act"), John 

Trigg (the "applicant"), operator of a Small Unmanned Aircraft Systems ("sUAS") seeks an exemption 

from the Federal Aviation Regulations ("FARs") to allow for commercial operation for aerial still 

photography and video. The sUAS (DJI Inspire 1) will be used to capture high quality images for 

Electronic News Gathering (ENG), media, advertising, homes, properties and vacant land for sale in 

Las Vegas, NV. The sUAS will be flown safe, efficiently and at or below 200 ft. all times.

The DJI Inspire 1

The DJI Inspire 1 is a small, unmanned multirotor aircraft, weighing 6.5 lbs., inclusive of

batteries and technical payload. The rotorcraft can operate at a speed up to 43 knots (50 mph).

The sUAS will have the following specifications:

Airframe: DJI Inspire 1

Dimensions: 438x451x301mm / 17.24 x 17.75 x 11.85 in.

Flight Control System: Internal to the DJI Inspire 1 and included with the main controller (MC).

The main controller receives the battery voltage, capacity, and current, the internal measurement unit 

(IMU), which receives telemetry data (visible at the ground station), compass, GPS, radio receiver (RX).

Transmitter (Tx): DJI Inspire Remote Control

Receiver (Rx): Internal to DJI Inspire 1

Motor: DJI 3510

Propeller: DJI 1345, 13-inch diameter

Data and Video Combined Link: HD Lightbridge Video Downlink

Gimbal: Zenmuse X3

Camera: X3 FC350

Batteries: LiPo 6S High voltage battery with 4500 mAh capacity
Applicant:

John Trigg

1200 W. Cheyenne Ave

Unit 2013

Las Vegas, NV 89030

Attachments

1) DJI Inspire 1 Users Training Manual

2) DJI Inspire 1 Maintenance Manual

3) DJI Inspire 1 Safety Guidelines

Regulations from which the exemption is requested:

14 CFR Part 21 subpart H

14 CFR45.23 (b)

14 CFR 91.7 (a)

14 CFR 91.9 (b) (2)

14 CFR 91.9 (c)

14 CFR 91.103 (b) (2)

14 CFR 91.105

14 CFR 91.109

14 CFR 91.113 (b)

14 CFR 91.121

14 CFR 91.203 (a) and (b)

14 CFR 91.403

14 CFR 91.405 (al

14 CFR 91.407 (a] (1)

14 CFR 91.409 (a) (2)

14 CFR 91.417 (a) and (b)

Extent of Relief I and Why

14 CFRPart 21 subpart H

The UAS to be operated carries neither pilot nor passenger and carries no explosive materials or 

flammable liquids. Given the size, weight, speed and limited operating area associated with the aircraft to 

be utilized, I request exception. In the restricted environment and under the conditions proposed 

operation will be at least as safe, or safer, than a conventional aircraft operating with an airworthiness 

certificate without said restrictions.

14 CFR45.23 (b)

Due to the size of this UAS it does not have a cockpit, cabin, or pilot station on which to market certain 

words or phrases. Lettering would be very difficult to place on such a small aircraft and dimensions would 

need to be smaller than required minimums.

14 CFR91.7 (a)

As there will be no airworthiness certificate for the aircraft, should this exemption be granted, no FAA

regulatory standard will exist for determining airworthiness. Given the size of the aircraft for maintenance 

and use of safety check list prior to each flight an equivalent level of safety will be provided.
14 CFR91.9 (b) (2)

Given the size and configuration, the UAS has no ability to carry a flight manual on the aircraft. There is 

no room capacity, or pilot on board to adequately carry flight manual. An equivalent level of safety will be

maintained by keeping the flight manual at ground control point where the pilot will have immediate 

access to it.

14 CFR91.103

As FAA approved flight manuals will not be provided for the aircraft an exemption will be needed. Normal

procedures including but not limited to; reviewing weather, flight battery requirement, landing and

takeoff distances, along will all of those found in attachment " Pilot Training". An equivalent level of safety

will be provided by preflight protocol to properly match the machine.

14 CFR91.109

UAS and remotely piloted aircraft do not have fully functional dual controls. Flight control is achieved 

through the use of a control box that communicates with the aircraft via radio communications. The 

equivalent level of safety provided because neither a pilot nor passenger will be carried in the aircraft, and 

by the speed and size of the aircraft.

14 CFR91.113 (a) and (b)

I can achieve an equivalent level of safety as achieved by current regulations because my sUAS does not

carry a pilot or passengers. While helpful, a pilots' license will not ensure remote control piloting skills.

14 CFR91.121

The sUAS may not have a barometric altimeter, but instead does have a GPS altitude read out. I believe 

an exemption may be needed. An equivalent level of safety is achieve by the operator receiving live flight

data monitoring and confirming current altitude along with altitude of launch site shown on GPS

altitude indicator.

14 CFR91.203 (a) and (b)

Similar to, 14 CFR91.9 (b) (2), given the size and configuration, the UAS has no ability to carry certificate 

and registration documents on the aircraft. An equivalent level of safety will be achieved by keeping these

documents, to the extent they are applicable to the UAS, at the ground control point where pilot has

immediate access to them.

14 CFR91.405 (a), 14 CFR91.407 (a) (1), 14 CFR91.409 (a) (2), 14 CFR91.417 (a) and (b)

Given these sections only apply to aircraft with an airworthiness certificates, theses sections do not apply 

to this applicant. As a safety precaution, operator will perform preflight inspections and ensure UAS is in 

working condition before initiating each flight. John Trigg is seeking relief from all FARs above preventing 

applicant from conducting aerial photography and video of real estate taken at levels less than 400ft, at a 

speed less than 30 mph, and with a maximum flight time of less then 30 minutes,. The drone to be used 

is less then 15 pounds. The weight of the UAS meets the definition of "small unmanned aircraft" found in 

section 331.
"The Reform Act".

In order to obtain high quality photography and video the sUAS will be used at speeds

much less than it's top speed of 50mph. Due to the sUAS being battery powered there are no combustible

fuels onboard. Maximum flight time for this particular sUAS is less than 30 minutes. Flights are to be 

terminated with no less than 25% battery life remaining. Given the size, weight, speed, and limited 

operating area associated with the aircraft to be utilized I find this exception to be reasonable with an 

equivalent or greater level of safety to be reached by the operator.

Safety

Please see attachment 3 “DJI Inspire 1 Safety Guidelines” for safety precautions to be use for every flight.

Additionally:

1) Applicant has been flying 6-channel RC helicopters and drones for over eight years and is an 

Open Member (# 1066746) in good standing with the AMA (Academy of Model Aeronautics)

2) Applicant has more than 25 years in news gathering, television and film industries

3) I will not operate within 5 miles of an airport unless prior contact to Air Traffic Control or the 

airport manager has been made.

4) I will land my sUAS prior to manufacturer recommended minimum level of battery power.

5) I will pilot my sUAS through remote control by line of sight.

6) My sUAS uses GPS and a flight safety feature whereby it returns to a preprogrammed position 

and then slowly lands if communication with the remote control pilot is lost.

7) I actively analyze flight data and other sources of information to constantly update and enhance 

safety protocols.

8) I conduct extensive pre-flight inspections and protocol, during which safety carries primary

importance.

9) I always obtain all necessary permissions prior to operation.

10) I have procedures in place to abort flights in the event of safety breaches or potential danger.

Public Interest

Aerial videography for geographical awareness, television, film, commercial and real estate marketing 

has been around for a long time through manned fixed wing aircraft and helicopters. For small business 

owners, its expense has been cost-prohibitive. Granting this exemption would allow me to provide this 

service at a much lower cost. 

The use of an sUAS in the real estate industry provides both buyers and sellers a higher level of service. 

For a buyer a higher level of marketing and advertising is achieved appealing to more buyers, resulting in 

a quicker sale of their home. Quicker home sales also helps accelerate the economy as a whole. Buyers

experience the benefit of encompassing a whole property, sometimes several acres, in one photo or a 

short video. Not only does this benefit the specific home seller or home buyer, but it benefits the general

public because it is much more efficient than traditional ways of using a plane or helicopter to achieve

the same result. We can now provide this level of service while being conservative with fuel, time, 

emissions, noise, and other resources. Considering size, weight, speed, and absence of combustible 

fuels, my sUAS will poses much less of a safety concern for the general public when compared to 

manned aircraft.

Thank you for your consideration,

John Trigg

eMail: john46652@gmail.com