1 December, 29 2015 Attn: U. S. Department of Transportation Docket 

Operations West Building Ground Floor, Room w12-140 1200 New Jersey 

Ave, SE Washington, DC 20590 RE: The Hover Bureau

REQUEST AN EXEMPTION FROM THE REQUIREMENTS OF TITLE 

14 OF THE CODE OF FEDERAL REGULATIONS 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) CONCERNING COMMERCIAL 

OPERATION OF UNMANNED AIRCRAFT SYSTEMS DJI Inspire 1

PURSUANT TO SECTION 333 OF THE FAA MODERNIZATION AND 

REFORM ACT OF 2012 (PUBLIC LAW 112-95) 

Robert Borges Partner, The Hover Bureau 6809 Pine Street, Longboat Key, 

FL 34228 619-618-9481 robert@thehoverbureau.com 2 TABLE OF 

CONTENTS Page 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) 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 4 

The Hover Bureau seeks 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), to operate an Unmanned Aircraft 

System (DJI Phantom 3) pursuant to Section 333 of the FAA Modernization 

and Reform Act of 2012 (FMRA). This exemption will permit The Hover 

Bureau to operate an Unmanned Aircraft System (UAS) for the commercial 

purpose of conducting aerial video and photography of residential and 

commercial real estate, over certain areas of the United States. 

INTRODUCTION AND INTERESTS OF THE PETITIONER The Hover 

Bureau has an expertise and knowledge in video and multimedia marketing, 

and advertising. The objective of The Hover Bureau and our Unmanned 

Aircraft System (DJI Inspire 1) aerial operations is to provide a more 

affordable, high-quality production system for a variety of real estate 

marketing activities. 
The Hover Bureau UAV will be operated always within eyesight of the 

operator who is in the process of taking FAA approved flight safety classes. 

Capturing video of real estate properties requires that the UAV is operated 

slowly and at a relatively low altitude as to capture all the amenities and 

features of said properties for prospective buyers to view.

The Hover Bureau seeks an exemption to operate DJI Inspire 1 system for 

compensation or hire within the NAS. The DJI Inspire 1 is 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 is equipped with four main rotors; driven by Lithium Polymer 

battery powered electric motors. 5 The DJI Inspire 1 that will be operated by 

The Hover Bureau 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, The Hover 

Bureau, 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, The 

Hover Bureau operation of DJI Inspire 1 UAS 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 THE HOVER 

BUREAU. Accordingly, The Hover Bureau 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. The Hover Bureau submits that the 

requested relief is proper since an equivalent level of safety will be ensured. 

The Hover Bureau 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 operating documents 

(i.e., Monthly Maintenance Log, and DJI Inspire 1 Instruction Manual). 

Furthermore, The Hover Bureau will document and maintain all 

maintenance records for the DJI Inspire 1 UAS. Relief from certain 

requirements of Section 61.113(a) and (b), entitled Private pilot privileges 
and limitations: Pilot in command, is requested by The Hover Bureau to the 

extent necessary to allow a Pilot in Command (PIC) holding a private pilot 

or higher level certificate, as well as an airman medical certificate, and who 

has demonstrated, by meeting minimum flighthour and currency 

requirements, that the PIC is able to safely operate the DJI Phantom UAS in 

a manner consistent with this exemption, including evasive and emergency 

maneuvers and maintaining appropriate distances from people, vessels, 

vehicles and structures. The Hover Bureau seeks relief from Section 91.7(a), 

entitled Civil aircraft airworthiness, because the DJI Inspire 1 UAS do not 

require an airworthiness certificate in accordance with 14 C.F.R. Part 21, 

Subpart THE HOVER BUREAU. As such, The Hover Bureau submits that 

they will ensure that the DJI Inspire 1 UAS is in an airworthy condition, 

prior to every flight, by determining that the UAS are in compliance with the 

operating documents (i.e., Monthly Maintenance Log, and DJI Inspire 1

Instruction Manual), and that the aircraft are in a condition for safe flight. 6 

The Hover Bureau 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 The Hover Bureau 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. 

Additionally, The Hover Bureau seeks an exemption from the requirements 

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

conditions. The Hover Bureau 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 18 minutes. 

Battery power indicators are also able to show exactly how much battery 

power is left, as well as how much time is needed to return safely back to 

point of take off. In accordance with 14 C.F.R. § 11.81, The Hover Bureau

provides the following information in support of its petition for exemption: 

A. Name And Address Of The Petitioner. 

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

Borges Partner of The Hover Bureau LLC 6809 Pine Street, Longboat, Key, 

FL 34228. 619-618-9481 robert@thehoverbureau.com The Specific Sections 

Of 14 C.F.R. From Which The Hover Bureau Seeks Exemption. 1. The 
Hover Bureau 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 (PIC) 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. The Hover Bureau 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. 3. The Hover 

Bureau 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. 8 4. 

The Hover Bureau 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: (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. 5. The Hover Bureau 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[.] 6. The Hover Bureau 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[.] 7. The Hover 

Bureau 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 8. 

The Hover Bureau Seeks Exemption From The Requirements Of Sections 

91.417(a) And 91.417(b). Section 91.417, entitled Maintenance records, 

subsections (a) and (b), state 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: (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. 10 (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 The Hover Bureau

Seeks And The Reason The Hover Bureau Seeks The Relief. 1. Extent Of 

Relief The Hover Bureau Seeks And The Reason The Hover Bureau 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 a private pilot or 

higher level certificate, as well as a current and valid airman medical 

certificate, 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, The Hover Bureau 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, The Hover Bureau 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 The Hover Bureau business; and (2) will not carry 

passengers or property for compensation or hire. 11 2. Extent Of Relief The 

Hover Bureau Seeks And The Reason The Hover Bureau 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 The Hover Bureau 

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 operating 

documents (i.e., the Hover Bureau Aerial Operations Manual, Monthly 

Maintenance Log, and DJI Inspire 1 Instruction Manual). The Hover Bureau

seeks the requested relief because the DJI Inspire 1 UAS do not require an 

airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart THE 
HOVER BUREAU. Therefore, The Hover Bureau will ensure that the DJI 

Inspire 1 UAS are in airworthy condition based upon its compliance with the 

operating documents (i.e., Monthly Maintenance Log, and DJI Inspire 1) 

prior to every flight, and further, determine that the aircraft are in condition 

for safe flight, as stated in the conditions and limitations below. 3. Extent Of 

Relief The Hover Bureau Seeks And The Reason The Hover Bureau 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), The 

Hover Bureau seeks the requested relief because the DJI Inspire 1 UA’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 are 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. 4. Extent Of Relief The Hover Bureau Seeks And The 

Reason The Hover Bureau 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 18

minutes. The Hover Bureau 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 The Hover Bureau 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 The Hover Bureau’s proposed operating limitations, ensure 

that The Hover Bureau 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 18 minutes. 5. Extent Of Relief The Hover Bureau Seeks And 
The Reason The Hover Bureau 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, The Hover Bureau

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, The Hover Bureau 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 The Hover Bureau

Aerial Operations Manual, Monthly Maintenance Log, and DJI Inspire 1 

Instruction Manual). Furthermore, The Hover Bureau will document and 

maintain all maintenance records for the DJI Inspire 1 UAS. D. The Reasons 

Why Granting The Hover Bureau Request Would Be In The Public Interest; 

That Is, How It Would Benefit The Public As A Whole. Granting the present 

Petition will further the public interest by allowing The Hover Bureau to 

safely, efficiently, and economically perform aerial video and photography 

of real estate, events and civic landscape over certain areas of the United 

States will enable real estate professionals to showcase their properties in a 

compelling manner helping to facilitate real estate transactions which will 

ultimately generate tax revenue for the state of Florida.

Additionally, use of the DJI Inspire 1 UAS will decrease congestion of the 

NAS, reduce pollution, and provide significant benefits to the economy. 

Notably, the benefits of The Hover Bureau’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 13 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 do 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. 

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 produces 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 

are propelled by battery powered electric motors, rather than an internal 

combustion engine. By using the DJI Inspire 1 UAS to perform aerial 

acquisitions, the substantial risk to life and 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 DJI 

Inspire 1 UAS (weighing approximately 2.8 pounds at their maximum gross 

weight with diagonal dimension of 23.2 inches, and with no fuel on board), 

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). 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 are 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 The Hover Bureau, 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 14 flexibility compared 

to manned 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 The Hover Bureau, 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, The Hover Bureau’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 Hover Bureau’s Aerial Operations Manual, Monthly 

Maintenance Log, and DJI Inspire 1 Instruction Manual) which requires 

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. 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 The Hover Bureau Seeks Exemption. 1. 

Reasons Why The DJI Inspire 1 UAS Meet 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, The Hover Bureau’s

operation of the DJI Inspire 1UAS meet the conditions of FMRA Section 

333, and will not require an airworthiness certificate in accordance with 14 

C.F.R. Part 21, Subpart THE HOVER BUREAU. 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 rulemaking required by section 332 of this Act or the guidance required 

by section 334 of this Act. 15 (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, The Hover Bureau 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 1UAS; (b) the 

pilot certification requirement; and (c) the specific operating limitations. a. 

The Specifications Of The DJI Inspire 1UAS 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. 

The DJI Inspire 1UAS Global Positioning Modes Enable The UAS To 

Remain Within A Defined Operational Area. The DJI Inspire 1 UAS may be 

operated in both manual and global positioning flight modes. The DJI 

Inspire 1 UAS Are Designed For Automatic Return To Home Point Or 

Hover In The Event Of Loss Of The Control Link Or Navigation. When the 

Control Link is lost, the DJI Inspire 1 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 UAS will assume that the 

Control Link is lost and the will return to the home position (i.e., failsafe 

mode) via GPS, and will descend to the takeoff position and shutdown. 16. 

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

A Certificated Pilot in Command With A Safety Observer. The Hover 

Bureau video production staff will be the only persons to act as a pilot in 

command (PIC) of the DJI Inspire 1UAS. c. Flights Of DJI Inspire 1 UAS 

Will Be Conducted Pursuant To Specific Operating Limitations. In seeking 

this exemption, The Hover Bureau 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 will be limited to the following aircraft described in the operating 

documents, rotorcraft UAS weighing less than 55 pounds maximum gross 

weight: DJI Inspire 1 Unmanned Aircraft Systems. Proposed operations of 

any other aircraft will require a new petition or a petition to amend this 
grant. 2. UAS operations under this exemption will be limited to conducting 

operations for the purpose of aerial video and photography. 3. The UAS may 

not be flown at an indicated airspeed exceeding 20 knots. 4. The UA must be 

operated at an altitude of no more than 400 feet above ground level (AGL), 

as indicated by the procedures specified in the operating documents unless a 

special request is made and approved by ATC. All altitudes reported to ATC 

must be in feet AGL. 5. The UAS 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 FAA-issued airman medical certificate. 6. The use of 

first person view (FPV) by the PIC or safety observer (SO) is not permitted. 

17 7. All operations must utilize a safety observer (SO). The SO may be 

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

VLOS capability. The SO 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 SO can perform the functions prescribed in the operating documents. 8. 

The SO must not perform any other duties beyond assisting the PIC with 

seeing and avoiding other air traffic and other ground based 

obstacles/obstructions and is not permitted to operate the camera or other 

instruments. 9. The operating documents and the grant of exemption must be 

accessible during UAS operations and made available to the Administrator 

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

contained in the grant of exemption and the procedures outlined in the 

operating documents, the conditions and limitations contained in the grant of 

exemption 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 upon request. The operator must also 

present updated and revised documents if it petitions for extension or 

amendment to the grant of exemption. If the operator determines that any 

update or revision would affect the basis upon which the FAA granted the 

exemption, then the operator must petition for 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. 

10. Prior to each flight the PIC must inspect the UAS to ensure that 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. 11. 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. The PIC who conducts the functional test flight must 

make an entry in the aircraft records. 12. The pre-flight inspection must 

account for all potential discrepancies, e.g. inoperable components, items, or 

equipment, not already covered in the relevant sections of the operating 

documents. 13. The operator must follow the UAS manufacturer’s 

aircraft/component, maintenance, overhaul, replacement, inspection, and life 

limit requirements. 18 14. The operator must carry out its maintenance, 

inspections, and record keeping requirements, in accordance with the 

operating documents. Maintenance, inspection, alterations, and status of 

replacement/overhaul component parts must be noted in the aircraft records, 

including total time in service, description of work accomplished, and the 

signature of the authorized person returning the UAS to service. 15. Each 

UAS operated under this exemption must comply with all manufacturer 

Safety Bulletins. 16. The authorized person must make an entry in the 

aircraft record of the corrective action taken against discrepancies 

discovered between inspections. 17. The PIC must possess at least a private 

pilot certificate and at least a current thirdclass medical certificate. 18. The 

operator may not permit any PIC to operate unless the PIC meets the 

operator’s qualification criteria and 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 persons, vessels, vehicles and structures. PIC 

qualification flight hours must be logged in a manner consistent with 14 

C.F.R. § 61.51(b). Flights for the purposes of training the operator’s PICs 

are permitted under the terms 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, and the PIC 

must operate the UA with appropriate distance from nonparticipants in 

accordance with 14 C.F.R. § 91.119. 19. UAS operations may not be 

conducted during night, as defined in 14 C.F.R. § 1.1. All operations must 

be conducted under visual meteorological conditions (VMC). If flight at 

night is required, a special request will be made at the FAA office closest to 

proposed area of operations. Flights under special visual flight rules (SVFR) 
are not authorized. 20. The UA may not operate within 5 nautical miles of an 

airport reference point as denoted on a current FAA-published aeronautical 

chart unless a letter of agreement with that airport’s management is 

obtained, and the operation is conducted in accordance with a NOTAM as 

required by the operator’s COA. The letter of agreement with the airport 

management must be made available to the Administrator upon request. 21. 

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. 22. If the UA loses communications or loses its GPS signal, it must 

return to a predetermined location within the planned operating area and 

land or be recovered in accordance with the operating documents. 19 23. 

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

emergencies in accordance with the operating documents. 24. The PIC is 

prohibited from beginning a flight unless (considering wind and forecast 

weather conditions) there is enough power to fly at normal cruising speed to 

the intended landing point and land the UA with 25% battery power 

remaining. 25. The operator 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 the operation. All operations 

shall be conducted in accordance with airspace requirements in the ATO 

issued COA including class of airspace, altitude level and potential 

transponder requirements. 26. All aircraft operated in accordance with the 

exemption must be identified by serial number, registered in accordance 

with 14 C.F.R. part 47, and have identification (NNumber) markings in 

accordance with 14 C.F.R. part 45, Subpart C. Markings must be as large as 

practicable. 27. 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. 28. The documents required fewer than 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 UAS is operating. These documents must 

be made available to the Administrator or any law enforcement official upon 

request. 29. The UA must remain clear and yield the right of way to all 

manned aviation operations and activities at all times. 30. The UAS may not 

be operated by the PIC from any moving device or vehicle. 31. Flight 

operations must be conducted at least 500 feet from all nonparticipating 

persons (persons other than the PIC, SO, operator trainees or essential 

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 and/or; b. The aircraft 

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, and; 20 c. Operations 

nearer to the PIC, SO, operator trainees or essential persons do not present 

an undue hazard to those persons per § 91.119(a). 32. 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 for each flight 

to be conducted. 33. 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: The Hover Bureau.ntsb.gov. 2. Reasons Why An 

Exemption From The Requirements Of Section 61.113(a) And (b) Would 

Not Adversely Affect Safety. The Hover Bureau 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 Phantom 3 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 1UAS in a 

manner consistent with the exemption, including evasive and emergency 

maneuvers and maintaining appropriate distances from people, vessels, 

vehicles and structures. Considering The Hover Bureau’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. 11062); and the airmanship skills 

necessary to safely operate the DJI Inspire 1UAS, The Hover Bureau

submits that the additional manned airmanship experience of a commercially 

certificated pilot would not correlate to the airmanship skills necessary for 

The Hover Bureau’s specific proposed flight operations. 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). The Hover Bureau will not allow any PIC to operate the DJI Inspire 

1 UAS unless that PIC has demonstrated, by meeting minimum flight-hour 

requirements or the DJI Inspire 1 UAS training 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. Specifically, the PIC must have accumulated and logged, in a 

manner consistent with 14 C.F.R. § 61.51(b), 25 hours of total time as a 

UAS rotorcraft pilot (with a minimum of 5 hours of those 21 hours as a UAS 

pilot operating the same make and model of UAS to be used for operations 

under the exemption). In addition to the hour requirements, the PIC must 

accomplish 3 takeoffs and landings in the preceding 90 days (for currency 

purposes). 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 The 

Hover Bureau’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, The Hover Bureau 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 

Phantom 3 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. 22 The equivalent level of safety established by 

Section 91.7(a) will be maintained because prior to every flight, The Hover 

Bureau will ensure that the DJI Inspire 1 UAS is in an airworthy condition 

based upon the UAS’s compliance with its operating documents and as 

stated in the conditions and limitations herein. 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 1UAS 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 The Hover Bureau’s

operation of the DJI Inspire 1 UAS 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 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, The Hover Bureau
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 18 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 23 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 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, The Hover Bureau 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 The Hover Bureau will use trained 

technicians to perform maintenance, alterations, or preventive maintenance 

on the UAS using the methods, techniques, and practices prescribed in the 

operating documents (i.e., the Hover Bureau Aerial Operations Manual, 

Monthly Maintenance Log, and DJI Inspire 1 Instruction Manual). 

Furthermore, The Hover Bureau will document and maintain all 

maintenance records for the DJI Inspire 1UAS. Since the DJI Inspire 1 UAS 

will be inspected as prescribed by the operating documents, The Hover 

Bureau will maintain the equivalent level of safety established by Sections 

91.405(a), 91.409(a)(1), and 91.409(a)(2). Likewise, the exemption sought 

will not adversely affect safety because The Hover Bureau will use trained 

technicians to perform maintenance, alterations or preventive maintenance 

on the UAS using the methods, techniques, and practices prescribed by the 
operating documents. 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 DJI Inspire 1UAS will be 

performed by trained technicians. Maintenance will be documented and 

maintained utilizing the monthly maintenance log. 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. 24 In consideration of The Hover 

Bureau’s proposed operating limitations, the operating documents, and the 

technical aspects of the DJI Inspire 1 UAS, The Hover Bureau 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). 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). 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, The Hover Bureau 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 THE HOVER BUREAU, 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 

Leading Edge’s 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 

THE HOVER BUREAU, and 14 C.F.R Sections 25 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). • A Summary That Can Be Published In The Federal 

Register, stating: The Rules From Which The Hover Bureau Seeks 

Exemption: The Hover Bureau seeks exemption from the requirements of 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). A Brief 

Description Of The Nature Of The Exemption The Hover Bureau Seeks: 

This exemption will permit The Hover Bureau to commercially operate an 

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

video and photography over certain areas of the United States. • Any 

Additional Information, Views, Or Arguments Available To Support The 

Hover Bureau’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, The Hover Bureau’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, The Hover Bureau 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, The Hover Bureau seeks an exemption 

pursuant to 14 C.F.R. § 11.61 and Section 333 of the FAA Modernization 

and Reform Act of 2012 (FMRA), which will permit safe operation of the 

DJI Inspire 1 UAS commercially, without an airworthiness certificate, for 
the limited purpose of conducting aerial video and photography over certain 

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 The Hover Bureau to safely, efficiently, and economically operate 

the DJI Inspire 1 UAS commercially within the NAS. 26 WHEREFORE, in 

accordance with the Federal Aviation Regulations and the FAA 

Modernization and Reform Act of 2012, Section 333, The Hover Bureau

respectfully requests that the Administrator grant this Petition for an 

exemption from the requirements of 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), and permit The Hover Bureau to operate the DJI 

Inspire 1 UAS commercially for the purpose of conducting aerial video and 

photography over certain areas of the United States. Dated: December 29, 

2015 Respectfully submitted, Robert Borges, Partner The Hover Bureau 

LLC, 6809 Pine Street, Longboat Key, FL 34228 619-618-9481 

robert@thehoverbureau.com