11 HAItPER 1VIEYER 11 

Attorneys at Law 

KATIE DELUCA 

kdeluca@harpermeyer.com 

305.577.3443 Ext. 235 

October 14, 2015 

U.S. Department of Transportation 

Docket Management System 

1200 New Jersey Ave., S.E. 

West Building Ground Floor, Room W12-140 

Washington, DC 20590 

Re: Request for Exemption under Section 333 of the FAA Modernization and Reform 

Act, 49 U.S.C. 44701(f) and 14 C.F.R. Part 11 

Dear Sir or Madam, 

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

and 14 C.F.R. Part 11, Inflight Solutions LLC ("Inflight") seeks exemption from the Federal 

Aviation Regulations ("FARs") listed herein to allow for the commercial operation of its small 

Unmanned Aircraft Systems ("UAS") to conduct of aerial videography and photography for real 

estate, architecture, land surveying and mapping, precision agriculture, television, public events, 

cinematography, news gathering, and aerial inspection and photography of residential and 

commercial structures, so long as such operations are conducted within and under the conditions 

outlined herein or as may be established by the FAA. Inflight does not intend to operate its UAS 

outside the United States. Inflight's Pilot in Command ("PIC") has over fifteen years of 

experience with model aeronautics, including model airplanes and helicopters. Inflight's 

operations team has over four years of experience with UAS equipment. 

The requested exemption would permit the operation of small, unmanned and relatively 

inexpensive UAS under controlled conditions in an airspace that is limited, predetermined and 

controlled as to access; and would provide a safe, efficient, economical and environmentally 

friendly alternative to conventional aircraft traditionally used to obtain aerial imagery. Approval 

of this petition would thereby enhance safety and fulfill the Secretary of Transportation's 

responsibilities to "...establish requirements for the safe operation of such aircraft systems in the 

national airspace system." Section 333(c) of the FMRA. 

Inflight respectfully requests that the FAA waive the publication and comment 

procedures and grant this petition in a summary fashion, as (i) Inflight will comply with 

conditions and limitations substantially similar to, if not the same as, those in recently granted 

exemptions; (ii) the requested exemption would not set a precedent; and (iii) any delay on acting 

on this request for exemption would be detrimental to Inflight. 

I3ARPER MEYER PEREZ HAGEN O'CONNOR ALBERT & DRIBIN LLP 

Suite 800 • 201 South Biscayne Boulevard Miami, Florida 33131 

Telephone: 305.577.3443 • Facsimile: 305.577.9921 Web site: www.harpermeyer.com 
11 HARPER MEYER II 

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Page 2 

Petitioner's Contact Information: 

Inflight Solutions, LLC 

2000 S. Dixie Hwy, Suite 205B 

Miami, FL 33133 

Attn: Eduardo de Aguiar 

Phone: 786-505-6901 

Email: egfd.aguiar@gmail.com 

Harper Meyer Perez Hagen O'Conner Albert & Dribin LLP 

201 S. Biscayne Boulevard, Suite 800 

Miami FL, 33131 

Attn: Katie DeLuca 

Phone: 305-577-3443 

Email: kdelucagharperineyer.com 

Regulations from which the Exemption is Requested: 

14.C.F.R § 61.101(e)(4) & (e)(5) 

14.C.F.R. § 61.113(a) & (b) 

14.C.F.R § 61.23(a) & (c) 

14.C.F.R § 61.315 

14.C.F.R. §91.119 

14.C.F.R. § 91.121 

14.C.F.R. § 91.151(a) 

14.C.F.R. § 91.405(a) 

14.C.F.R. § 91.407(a)(1) 

14.C.F.R. §91.409(a) 

14.C.F.R. § 91.417(a) and (b) 

This exemption application is expressly submitted to fulfill the Congressional mandate in 

Section 333 of the FMRA to accelerate the introduction of commercial unmanned aircraft 

systems into the national airspace system ("NAS") if it can be accomplished safely. This law 

directs the Secretary of Transportation to consider whether certain UAS may operate safely in 

the NAS before completion of the rulemaking required under Section 332 of the FMRA. In 

inaking this determination, the Secretary of Transportation is required to determine which types 

of UAS do not create a hazard to users of the NAS or the public or pose a threat to national 

security in light of the following: 

• The weight, size, speed and operational capabilities of the UAS; 

HARPER MEYER PEREZ HAGEN O'CONNOR ALBERT & DRIBIN LLP 

Suite 800 • 201 South Biscayne Boulevard Miami, Florida 33131 

Telephone: 305.577.3443 • Facsimile: 305.577.9921 Web site: www.harpermeyer.com 
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• Whether the UAS will be operated in close proximity to airports or populated areas; and 

• Whether the UAS will be operated within the visual line of sight of the operator 

("VLOS"). Section 333(a)(1) of the FMRA Reform Act § 333(a)(1). 

The Federal Aviation Act expressly grants the Secretary of Transportation the authority 

to grant exemptions from the agency's safety regulations and minimum standards when the 

Secretary decides a requested exemption is in the public interest. See 49 U.S.C. §§ 106 (f), 

44701-44716, et. seq. 

Inflight's UAS weigh 55 lbs. or less, including payload and will be operated at a speed of 

no more than 87 knots. They will operate only within VLOS over private property, under the 

conditions and limitations set forth herein. Given the small size of the UAS and the restricted 

envirorunent in which they will operate, Inflight falls squarely within that zone of safety (an 

equivalent level of safety) in which Congress envisioned that the FAA must, by exemption, 

allow commercial operations of UAS to commence immediately. Additionally, due to the size of 

the UAS and the restricted environment in which they will operate, approval of Inflight's petition 

presents no national security issue. The grant of exemption is in the public interest based on the 

clear direction in Section 333 of the FMRA, the authority contained in the Federal Aviation Act, 

as amended, the strong equivalent level of safety surrounding Inflight's proposed operations, and 

the significant public benefit, including enhanced safety and reduction in environmental impacts, 

including reduced emissions, to be realized as a result of the use of the UAS in Inflight's aerial 

videography and photography operations. Accordingly, Inflight respectfully requests that the 

FAA grant the requested exemption without delay. 

Unmanned Aircraft Systems: 

Inflight seeks an exemption to operate the following five UAS for compensation or hire 

within the NAS: (i) the DJI S1000; (ii) DJI Inspire 1; (iii) Aeromapper 300; (iv) Cinestar 8 HL; 

and (v) the Freefly ALTA. The user manuals for each UAS have been submitted 

contemporaneously with this request for exemption. All UAS operated by Inflight will be 

registered in accordance with 14 C.F.R. Part 47. 

The UAS autonomous flight and navigation modes enable the UAS to remain within a 

defined operational area and are designed for automatic return to the home position in the event 

of loss of the control link or navigation. If the control link is lost or the minimum battery 

threshold has been exceeded, the UAS will automatically land or return to the point of launch via 

GPS, depending on the option selected. If automatic landing feature selected, the UAS begins a 

slow, safe and automatic descent and upon landing will shut down. If the return to point of 

launch feature is selected, the UAS will descend to the point of launch and shutdown. A 

complete description of the flight and navigational modes of the UAS and the failsafe functions 

of the UAS are set forth in the User Manuals attached hereto. 

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Suite 800 • 201 South Biscayne Boulevard Miami, Florida 33131 

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11 HARPER MEXER II 

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All flight operations proposed to be conducted by Inflight shall be performed by a team 

of three: a Pilot in Command ("PIC"); a Visual Observer ("VO"); and an engineer. All flights 

shall be conducted within the visual line of sight ("VLOS") of the PIC, within non-controlled 

airspace, at an altitude no greater than 400 feet AGL, and only over private property with the 

consent of the property owner and/or developer, as applicable. The Aeromapper 300 shall only 

be operated over rural areas. 

Conditions and Limitations 

In seeking this exemption, Inflight proposes commercially operate the UAS within its 

fleet, pursuant to the following specific operating limitations: 

1. Operations authorized by this grant of exemption will be limited to the UAS 

described herein, when weighing less than 55 lbs., including payload. Proposed 

operations of any other aircraft will require a new petition or a petition to amend this 

exemption. 

2. The UAS may not be operated at a speed exceeding 87 knots (100 miles per hour). 

Inflight may either use ground speed or calibrated airspace to determine compliance 

with the 87 knot speed restriction. In no case will the UAS be operated at airspeeds 

greater than the maximum UAS operating airspeed recommended by the aircraft 

manufacturer. 

3. The UAS must be operated at an altitude of no more than 400 feet AGL, which 

altitude shall be reported in feet AGL. 

4. The UAS must be operated within the VLOS of the PIC at all times. This requires the 

PIC to be able to use human vision unaided by any device other than corrective 

lenses, as specified on the PIC's FAA issued airman medical certificate or U.S. 

driver's license. 

5. All operations must utilize a visual observer ("VO"). The UAS must be operated 

within the 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. 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. 

6. The grant of exemption and all operating documents necessary to operate the UAS 

and conduct its operations in accordance with the conditions and limitations stated 

HARPER MEYER PEREZ HAGEN O'CONNOR ALBERT & DRIBIN LLP 

Suite 800 • 201 South Biscayne Boulevard Miami, Florida 33131 

Telephone: 305.577.3443 • Facsimile: 305.577.9921 Web site: www.harpermeyer.com 
11 HARPER MEYER II 

October 14, 2015 

Page 5 

herein must be accessible during UAS operations and made available to the 

Administrator upon request. If a discrepancy exists between the conditions and 

limitations in the grant of exemption and the procedures outlined in Inflight's 

operating documents, the conditions and limitations within the grant of exemption 

shall take precedence and must be followed. Otherwise, Inflight must follow the 

procedures as outlined in its operating documents. Inflight may update or revise its 

operating documents. It shall be Inflight's responsibility to track such revisions and 

present updated and revised documents to the Administrator and any law enforcement 

official upon request. Infight must also present updated and revised documents if it 

petitions for an extension or amendment to its grant of exemption. In the event 

Inflight determines that any update or revision would affect the basis upon which 'the 

FAA granted the exemption, than Inflight shall 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. 

7. 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 the 

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 not to pose an undue hazard to persons and 

property. 

8. Inflight shall be responsible for maintaining and inspecting the UAS to ensure that it 

is in a condition for safe operation. 

9. Prior to each flight, the PIC shall 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. 

10. Inflight must follow the UAS manufacturer's maintenance overhaul, replacement, 

inspection and life limit requirements for the aircraft and aircraft components. 

11.Each UAS operated under the exemption must comply with all manufacturer safety 

bulletins. 

12. The PIC must hold either a 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 

HARPER MEYER PEREZ HAGEN O'CONNOR ALBERT & DRIBIN LLP 

Suite 800 • 201 South Biscayne Boulevard Miami, Florida 33131 

Telephone: 305.577.3443 • Facsimile: 305.577.9921 Web site: www.harpermeyer.com 
11 HARPER MEYER II 

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Page 6 

by a state. The PIC must also meet the flight review requirements specified in 14 

C.F.R. § 61.56 in an aircraft in which the PIC is rated on his or her pilot certificate. 

13.Inflight 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 the exemption, including evasive and emergency maneuvers and maintaining 

appropriate distances from person, vessels, vehicle and structures. PIC qualification 

flight hours and currency must be logged in a manner consistent with 14 C.F.R. § 

61.51(b). Flights for the purposes of training Inflight'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 the 

grant of exemption are permitted under the terms of the grant of the 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 in accordance with 14 

C.F.R. §91.119. 

14. UAS operations shall not be conducted at night, as defined in 14 C.F.R. § 1.1. All 

operations must be conducted under visual meteorological conditions (VMC). Flights 

under special visual flight rules (SVFR) shall not be authorized. 

15. UAS 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 Inflight. The 

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

Administrator or any law enforcement official upon request. 

16. The UAS 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. 

17.If the UAS loses communications or loses its GPS signal, it must return to a predetermined location within the private or controlled-access property. 

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

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

weather conditions) there is enough available power for the UAS to conduct the 

intended operation and to operate after that for at least five minutes or with the 

reserve power reconunended by the manufacturer if greater. 

HARPER MEYER PEREZ HAGEN O'CONNOR ALBERT & DRIBIN LLP 

Suite 800 • 201 South Biscayne Boulevard Miami, Florida 33131 

Telephone: 305.577.3443 • Facsimile: 305.577.9921 Web site: www.harpermeyer.com 
11 HARPER MEYER 11 

October 14, 2015 

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20.Inflight must obtain an Air Traffic Organization ("ATO") issued Certificate of 

Waiver or Authorization ("COA") prior to conducting any operations under the grant 

of exemption. This COA will also require the operator to request a Notice to Airman 

(NOTAM) not more than 72 hours in advance, but not less than 48 hours prior to 

operation. All operations shall be conducted in accordance with the airspace 

requirements in the ATO issued COA including class of airspace, altitude level and 

potential transponder requirements. 

21. All UAS operated in accordance with the grant of exemption must be 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 possible. 

22. Documents used by Inflight to ensure the safe operation and flight of the UAS and 

any documents required under 14 C.F.R. §§ 91.9 and 91.203 must be available to the 

PIC at the Ground Control Station (GCS) of the UAS any time the UAS is operating. 

These documents must be made available to the Administrator or any law 

enforcement official upon request. 

23. The UAS must remain clear and yield the right of way to all manned aviation 

operations and activities at all times. 

24. The UAS may not be operated by the PIC from any moving device or vehicle. 

25. Flight operations must be conducted at least 500 feet from all nonparticipating 

persons (persons other than the PIC, VO, Camera Operator, Engineer, trainees or 

essential persons), vessels, vehicles and structures unless: 

a. Barriers or structures are present that sufficiently protect nonparticipating 

persons from the UAS and/or debris in the event of an accident. Inflight 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 UAS, flight operations must cease immediately and/or; 

b. The UAS is operated near vessels, vehicles or structures where the 

owner/controller of such vessels, vehicles or structures has granted permission 

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. 

26. All operations shall be conducted over private or controlled access property with 

permission from the property owner/controller or authorized representative. 

Permission from the property owner/controller or authorized representative will be 

obtained for each flight to be conducted. 

HARPER MEYER PEREZ HAGEN O'CONNOR ALBERT & DRIBIN LLP 

Suite 800 • 201 South Biscayne Boulevard Miami, Florida 33131 

Telephone: 305.577.3443 • Facsimile: 305.577.9921 Web site: www.harpermeyer.com 
11 HARPER MEXER 11 

October 14, 2015 

Page 8 

27. 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.<Y.,ov. 

Unless otherwise specified in the grant of exemption, the UAS, the UAS PIC and the 

UAS operations shall comply with all applicable parts of 14 C.F.R. including, but not limited to, 

Part 45, 47, 61 and 91. 

Statutory Criteria Provided in Section 333 

Each UAS proposed to be operated by Inflight weigh 55 ibs. or less, including payload, 

will never operate at a speed of more than 87 knots or at an altitude higher than 400 feet AGL. 

To maximize safety, no flight operations will be conducted by Inflight when wind speeds are in 

excess of 15 mph. Each UAS proposed to be operated by Inflight carry neither pilot nor 

passenger, carry no explosive materials or flammable liquid fuels, and operate within a restricted 

and circumscribed area. Unlike other civil aircraft, operations under this exemption will be 

tightly controlled and monitored by Inflight, in accordance with the conditions and limitations 

listed above, and under the requirements and in compliance with local public safety 

requirements. Utilizing the UAS in Inflight's proposed operations shall provide a greater degree 

of safety to the public and property owners than conventional operations using manned aircraft. 

Additionally, due to the size, speed of operation, location of operation and lack of explosive 

materials or flammable liquid fuels, there is no credible threat to national security posed by such 

UAS. 

The Federal Aviation Act (49 U.S.C. §44701 (f)) and Section 333 of the Reform Act 

both authorize the FAA to exempt aircraft from the requirements of an airworthiness certificate 

upon consideration of the size, weight, speed, operational capability and proximity to airports 

and populated areas of the particular UAS. Given the small size and operational capabilities, of 

the UAS and the restricted areas in which the UAS will be operated, an exemption from Part 21 

subpart H, Airworthiness Certificates, and 14 C.F.R. 91.7(a) is warranted. Operating the 

proposed UAS without an airworthiness certificate in a restricted environment pursuant to the 

proposed conditions and limitations will be at least as safe, if not safer, than a conventional 

aircraft operating with an airworthiness certificate that is not subject to such conditions and 

limitations. 

Since each UAS, fully loaded, weigh less than 55 pounds and are operated without an 

onboard pilot, there is no ability to place or carry certification and registration documents or to 

display them on the UAS. An equivalent level of safety will be achieved by keeping these 

documents at the ground control point ("GCP") where the PIC will have immediate access to 

them. 

HARPER MEYER PEREZ HAGEN O'CONNOR ALBERT & DRIBIN LLP 

Suite 800 • 201 South Biscayne Boulevard Miami, Florida 33131 

Telephone: 305.577.3443 • Facsimile: 305.577.9921 Web site: www.harpermeyer.com 
11 HARPER MEYER 11 

October 14, 2015 

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14 C.F.R. § 61.113(a) &(b): PRIVATE PILOT PRIVELEGES AND LIMITATIONS; 

PILOT IN COMMAND 

14 C.F.R. §61.101(e) (4) &(5): RECREATIONAL PILOT PRIVELEGES AND 

LIMIATIONS; PILOT IN COMMAND 

14 C.F.R. § 61.315(a): WHAT ARE THE PRIVILEGES AND LIMITATIONS OF MY 

SPORT PILOT CERTIFICATE 

Section 61.113(a) and (b) limit private pilots to non-commercial operations; Section 61. 

Section 61.101(e) (4) and (5) limit recreational pilots to non-commercial operations; and Section 

61.315(a) limit sport pilots to non-commercial operations. Inflight requests relief from the 

foregoing to the extent necessary to allow a PIC holding a sport pilot certificate or higher level 

certificate to conduct Inflight's proposed UAS flight operations for compensation or higher. 

In Exemption No. 11213, the FAA determined that holders of recreational and sport 

pilot certificates would be qualified to serve as PIC in unmanned aircraft operations, as the 

holders of such certificates (i) must demonstrate the same aeronautical knowledge relevant to 

unmanned aircraft operations as a holder of a private pilot certificate; and (ii) are subject to 

security screening by the Department of Homeland Security. 

An equivalent level of safety will be achieved because Inflight's PIC shall hold a 

recreational certificate or sport pilot certificate and shall not be allowed to operate the UAS 

unless that PIC has demonstrated, by meeting minimum flight-hour and currency requirements, 

that such PIC is able to safely operate the UAS in a manner consistent with this exemption, 

including evasive and emergency maneuvers and maintaining appropriate distances from people, 

vessels, vehicles and structures. Considering the restricted area of operation, the operating 

conditions and limitations set forth herein, the parallel nature of sport pilot aeronautical 

knowledge requirements to private pilot requirements (and by extension, pursuant to the 

reasoning within Exemption 11062, commercial pilot requirements), allowing operations as 

requested with a recreational pilot certificate or sport pilot certificate exceeds the present level of 

safety achieved by 14 C.F.R. Section 61.114 (a) and (b). 

14 C.F.R. § 61.23(a) &(c): OPERATIONS REQUIRING A MEDICAL CERTIFICATE: 

REQUIREMENTS AND DURATION 

Inflight requests relief from Section 61.23(a) and (c), to the extent necessary to allow a 

PIC holding a sport pilot certificate or higher level certificate, as well as a current and valid 

driver's license, to conduct the proposed UAS flight operations for compensation or hire. 

In Exemption No. 11213, the FAA (i) granted relief from Section 61.23(a) to allow and 

pilot holding a sport certificate or higher to operate a UAS with a U.S. issued driver's license in 

lieu of an FAA-issued medical certificate; and (ii) granted relief from Section 61.23(c) to allow 

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Suite 800 • 201 South Biscayne Boulevard Miami, Florida 33131 

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11 HARPER MEYER II 

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sport pilot certificate holders to operate aircraft other than LSA with a U.S. issued driver's 

license. 

As each UAS, fully loaded, weighs less than 55 lbs. and will be operated within the 

VLOS of the PIC, at an altitude below 400 feet AGL, over a restricted area and subject to the 

conditions and limitations set forth herein, an equivalent level of safety will be achieved by 

requiring a PIC holding a recreation pilot certificate or sport pilot certificate, to operate the UAS 

with a U.S. issued driver's license. 

14 C.F.R. § 91.119 MINIMUM SAFE ALTITUDES 

Section 91.119 establishes safe altitudes for operation of civil aircraft. Inflight requests 

relief from Section 91.119 to the extent necessary to permit Inflight to operate UAS at altitudes 

up to 400 feet AGL. As set forth herein, the UAS will never operate at an altitude higher than 

400 feet AGL. 

The equivalent level of safety will be achieved given the size, weight and speed of the 

UAS. Additionally all operations will be conducted over private and/or controlled access 

property with the permission of the property owner or local officials, as applicable. Because of 

advance notice to the property owner and participants in the filming activity, all affected 

individuals will be aware of the flight operations. 

Compared to flight operations with conventional aircraft weighing far more than the 

maximum 55 lbs. proposed herein, carrying flammable fuel, any risk associated with these 

operations will be significantly less than those currently allowed with such conventional aircraft 

operating at or below 500 feet AGL. In addition, the low-altitude operations of the UAS will 

ensure separation between UAS operations and operations of conventional aircraft that must 

comply with Section 91.119. 

14 C.F.R. § 91.121: ALTIMETER SETTINGS 

This regulation requires each person operating an aircraft to maintain cruising altitude by 

reference to an altimeter that is set "...to the elevation of the departure airport or an appropriate 

altimeter setting available before departure." As the UAS may not have a barometric altimeter, 

but instead a GPS altitude read out, an exemption from Section 91.121 may be necessary. An 

equivalent level of safety will be achieved because the altitude information of the UAS will be 

provided to the PIC via GPS equipment and a radio communications telemetry data link, which 

downlinks from the UAS to the GCS from activing monitory of the flight path and altitude, and 

the PIC shall confirm the altitude of the launch site shown on the GPS altitude indicator prior to 

each flight operation. This altitude information, combined with Inflight's operation of the UAS 

within the VLOS, at an altitude at or below 400 feet AGL, will ensure a level of safety 

equivalent to Section 91.121. 

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14 C.F.R. § 91.151(A): FUEL REQUIREMENTS FOR FLIGHT IN VFR CONDITIONS 

Section 91.141(a) prohibits an individual from beginning "a flight in airplane under VFR 

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

fly to the first intended point of landing, and, assuming normal cruising speed-(1) During the 

day, to fly after that for at least 30 minutes or; (2) at night, to fly after that for at least 45 

minutes." 

The battery powering the DJI 1000 provides approximately 15 minutes of powered flight; 

the battery powering the DJI Inspire 1 provides approximately 18 minutes of powered flight; the 

battery powering the Aeromapper 300 provides approximately 1.5 hours of powered flight; the 

battery powering the Cinestar 8 HL provides approximately 15 minutes of powered flight; and 

the battery powering the Free Fly ALTA provides approximately 10 minutes of powered flight. 

Without an exemption from Section 91.515, the flight time duration of the battery powering the 

UAS would severely constrain the practicality of any aerial video or still photo flight operations 

that Inflight proposes to conduct pursuant to this exemption. In support of such exemption, 

Insight notes that the UAS are battery powered, are operated within the battery capacity of the 

UAS, and, with the exemption of the Aeromapper 300, are 'only operated for brief periods of 

time. Given the limitations on the proposed operations and their locations, an exemption from 

91.515 is warranted. 

14 C.F.R. § 91. 405(a); § 91.407(a)(1) ;§ 91.409(a); §91.417(a) &(b): MAINTENANCE 

INSPECTIONS 

Section 91.405(a) requires that an aircraft operator or owner "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..." Section 91.407 similarly makes reference to the requirements in Part 43. Section 

91.409 requires an annual inspection for the issuance of an airworthiness certificate. Section 

91.417 requires the owner or operator to keep records, showing certain maintenance work that 

has been accomplished by certified mechanics under Part 43, or licensed pilots, and records of 

approval of the aircraft for return to service. 

As these sections and Part 43 only apply to aircraft with an airworthiness certificate, 

these sections do not apply to Inflight as the proposed UAS do not require airworthiness 

certificates. An equivalent level of safety will be achieved because the UAS are small in size and 

will only operate in restricted areas for limited periods of time. Inflight will perform all 

maintenance and inspections in accordance with the operating documents and any required 

manufacturer safety or service bulletins, and conditions and limitations set forth herein; and will 

keep a log of any maintenance performed. In addition the PIC will conduct a pre-flight 

inspection of the UAS and all associated equipment to account for all discrepancies and/or 

inoperable components. Maintenance will be performed and verified to address any conditions 

HARPER MEYER PEREZ HAGEN O'CONNOR ALBERT & DRIBIN LLP 

Suite 800 • 201 South Biscayne Boulevard Miami, Florida 33131 

Telephone: 305.577.3443 • Facsimile: 305.577.9921 Web site: www.harpermeyer.com 
October 14, 2015 

Page 12 

potentially affecting safe operation of the UAS and no flights will occur unless and until the 

UAS has been found to be in a condition for safe operation. 

Conclusion 

The use of UAS for aerial videography and photography flight operations in lieu of 

conventional fixed wing and rotary aircraft benefits the public by decreasing congestion in the 

NAS, reducing air and noise pollution and increasing the safety of life and property in the air and 

on the ground. Additionally, the proposed operation of the UAS will not implicate any privacy 

issues, as all flights will occur under the conditions and limitations set forth herein. 

By granting the requested exemption, the FAA will be fulfilling the Congressional 

mandate of Section 333 of the FMRA, while also advancing the interests of the public, by 

allowing Inflight to safely, efficiently and economically operate the UAS commercially within 

the NAS. Additionally, the conditions and limitations proposed herein are substantially similar 

to, if not the same as, those in numerous grants of exemption previously issued by the FAA. 

Accordingly, Inflight respectfully requests that the FAA grant the requested exemption without 

delay. 

Sincerely yours, 

Katie DeLuca, Esq. 

HARPER MEYER PEREZ HAGEN O'CONNOR ALBERT & DRIBIN LLP 

Suite 800 • 201 South Biscayne Boulevard Miami, Florida 33131 

Telephone: 305.577.3443 • Facsimile: 305.577.9921 Web site: www.ljt-HW4AWV ~► aHVg ~~