June 8, 2015

Exemption No. 11772

Regulatory Docket No. FAA−2015−0916

Mr. Gregory S. Winton, Esq.

Counsel for RS&H, Inc.

The Aviation Law Firm

1997 Annapolis Exchange Parkway

Suite 300

Annapolis, MD 21401

Dear Mr. Winton:

This letter is to inform you that we have granted your request for exemption. It transmits our 

decision, explains its basis, and gives you the conditions and limitations of the exemption, 

including the date it ends.

By letter dated April 3, 2015, you petitioned the Federal Aviation Administration (FAA) on 

behalf of RS&H, Inc. (hereinafter petitioner or operator) for an exemption. The petitioner

requested to operate an unmanned aircraft system (UAS) to conduct geospatial data 

collection, aerial photography, infrastructure inspection services, and disaster area damage 

and debris assessments.

See Appendix A for the petition submitted to the FAA describing the proposed operations and

the regulations that the petitioner seeks an exemption.

The FAA has determined that good cause exists for not publishing a summary of the petition 

in the Federal Register because the requested exemption would not set a precedent, and any 

delay in acting on this petition would be detrimental to the petitioner.

Airworthiness Certification

The UAS proposed by the petitioner is a DJI Inspire 1.
2

In accordance with the statutory criteria provided in Section 333 of Public Law 112−95 in 

reference to 49 U.S.C. § 44704, and in consideration of the size, weight, speed, and limited 

operating area associated with the aircraft and its operation, the Secretary of Transportation 

has determined that this aircraft meets the conditions of Section 333. Therefore, the FAA

finds that relief from 14 CFR part 21, Certification procedures for products and parts, 

Subpart H—Airworthiness Certificates, and any associated noise certification and testing 

requirements of part 36, is not necessary.

The Basis for Our Decision

You have requested to use a UAS for aerial data collection1. The FAA has issued grants of 

exemption in circumstances similar in all material respects to those presented in your petition. 

In Grants of Exemption Nos. 11062 to Astraeus Aerial (see Docket No. FAA−2014−0352), 

11109 to Clayco, Inc. (see Docket No. FAA−2014−0507), 11112 to VDOS Global, LLC (see

Docket No. FAA−2014−0382), and 11213 to Aeryon Labs, Inc. (see Docket No. 

FAA−2014−0642), the FAA found that the enhanced safety achieved using an unmanned 

aircraft (UA) with the specifications described by the petitioner and carrying no passengers or 

crew, rather than a manned aircraft of significantly greater proportions, carrying crew in 

addition to flammable fuel, gives the FAA good cause to find that the UAS operation enabled 

by this exemption is in the public interest.

Having reviewed your reasons for requesting an exemption, I find that—

• They are similar in all material respects to relief previously requested in Grant of 

Exemption Nos. 11062, 11109, 11112, and 11213;

• The reasons stated by the FAA for granting Exemption Nos. 11062, 11109, 11112, and 

11213 also apply to the situation you present; and 

• A grant of exemption is in the public interest.

Our Decision

In consideration of the foregoing, I find that a grant of exemption is in the public interest. 

Therefore, pursuant to the authority contained in 49 U.S.C. 106(f), 40113, and 44701, 

delegated to me by the Administrator, RS&H, Inc. is granted an exemption from 14 CFR 

§§ 61.23(a) and (c), 61.101(e)(4) and (5), 61.113(a), 61.315(a), 91.7(a), 91.119(c), 91.121, 

91.151(a)(1), 91.405(a), 91.407(a)(1), 91.409(a)(1) and (2), and 91.417(a) and (b), to the 

extent necessary to allow the petitioner to operate a UAS to perform aerial data collection. 

This exemption is subject to the conditions and limitations listed below.

 

1 Aerial data collection includes any remote sensing and measuring by an instrument(s) aboard the UA. 

Examples include imagery (photography, video, infrared, etc.), electronic measurement (precision surveying, RF 

analysis, etc.), chemical measurement (particulate measurement, etc.), or any other gathering of data by 

instruments aboard the UA.
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Conditions and Limitations

In this grant of exemption, RS&H, Inc. is hereafter referred to as the operator.

Failure to comply with any of the conditions and limitations of this grant of exemption will be 

grounds for the immediate suspension or rescission of this exemption.

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

weighing less than 55 pounds including payload. Proposed operations of any other 

aircraft will require a new petition or a petition to amend this exemption.

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

not permitted. 

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

exemption holder may use either groundspeed or calibrated airspeed to determine 

compliance with the 87 knot speed restriction. In no case will the UA be operated at 

airspeeds greater than the maximum UA operating airspeed recommended by the 

aircraft manufacturer.

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

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

5. The UA must be operated within visual line of sight (VLOS) of the PIC at all times. 

This requires the PIC to be able to use human vision unaided by any device other than 

corrective lenses, as specified on the PIC’s FAA-issued airman medical certificate or 

U.S. driver’s license.

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

the visual line of sight (VLOS) of the PIC and VO at all times. The VO may be used 

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

capability. The VO and PIC must be able to communicate verbally at all times; 

electronic messaging or texting is not permitted during flight operations. The PIC 

must be designated before the flight and cannot transfer his or her designation for the 

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

required of the VO.

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

operations in accordance with the conditions and limitations stated in this grant of 

exemption, are hereinafter referred to as the operating documents. The operating 

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

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

limitations in this exemption and the procedures outlined in the operating documents, 

the conditions and limitations herein take precedence and must be followed. 
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Otherwise, the operator must follow the procedures as outlined in its operating 

documents. The operator may update or revise its operating documents. It is the 

operator’s responsibility to track such revisions and present updated and revised 

documents to the Administrator or any law enforcement official upon request. The 

operator must also present updated and revised documents if it petitions for extension 

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

or revision would affect the basis upon which the FAA granted this exemption, then 

the operator must petition for an amendment to its grant of exemption. The FAA’s 

UAS Integration Office (AFS−80) may be contacted if questions arise regarding 

updates or revisions to the operating documents.

8. Any UAS that has undergone maintenance or alterations that affect the UAS operation 

or flight characteristics, e.g., replacement of a flight critical component, must undergo 

a functional test flight prior to conducting further operations under this exemption. 

Functional test flights may only be conducted by a PIC with a VO and must remain at 

least 500 feet from other people. The functional test flight must be conducted in such 

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

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

in a condition for safe operation.

10. Prior to each flight, the PIC must conduct a pre-flight inspection and determine the 

UAS is in a condition for safe flight. The pre-flight inspection must account for all 

potential discrepancies, e.g., inoperable components, items, or equipment. If the 

inspection reveals a condition that affects the safe operation of the UAS, the aircraft is 

prohibited from operating until the necessary maintenance has been performed and the 

UAS is found to be in a condition for safe flight.

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

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

aircraft components.

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

safety bulletins.

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

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

current FAA airman medical certificate or a valid U.S. driver’s license issued by a 

state, the District of Columbia, Puerto Rico, a territory, a possession, or the Federal 

government. The PIC must also meet the flight review requirements specified in 

14 CFR § 61.56 in an aircraft in which the PIC is rated on his or her pilot certificate.

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

ability to safely operate the UAS in a manner consistent with how the UAS will be 
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operated under this exemption, including evasive and emergency maneuvers and 

maintaining appropriate distances from persons, vessels, vehicles and structures. PIC 

qualification flight hours and currency must be logged in a manner consistent with 

14 CFR § 61.51(b). Flights for the purposes of training the operator’s PICs and VOs 

(training, proficiency, and experience-building) and determining the PIC’s ability to 

safely operate the UAS in a manner consistent with how the UAS will be operated 

under this exemption are permitted under the terms of this exemption. However, 

training operations may only be conducted during dedicated training sessions. During 

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

flight operations are considered nonparticipants, and the PIC must operate the UA 

with appropriate distance from nonparticipants in accordance with 14 CFR § 91.119.

15. UAS operations may not be conducted during night, as defined in 14 CFR § 1.1. All 

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

under special visual flight rules (SVFR) are not authorized.

16. The UA may not operate within 5 nautical miles of an airport reference point (ARP) as 

denoted in the current FAA Airport/Facility Directory (AFD) or for airports not 

denoted with an ARP, the center of the airport symbol as denoted on the current 

FAA-published aeronautical chart, unless a letter of agreement with that airport’s 

management is obtained or otherwise permitted by a COA issued to the exemption 

holder. The letter of agreement with the airport management must be made available 

to the Administrator or any law enforcement official upon request.

17. The UA may not be operated less than 500 feet below or less than 2,000 feet 

horizontally from a cloud or when visibility is less than 3 statute miles from the PIC.

18. If the UAS loses communications or loses its GPS signal, the UA must return to a 

pre-determined location within the private or controlled-access property.

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

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

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

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

power recommended by the manufacturer if greater.

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

operations shall be conducted in accordance with an ATO-issued COA. The 

exemption holder may apply for a new or amended COA if it intends to conduct 

operations that cannot be conducted under the terms of the attached COA.

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

number, registered in accordance with 14 CFR part 47, and have identification 
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(N−Number) markings in accordance with 14 CFR part 45, Subpart C. Markings must 

be as large as practicable.

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

any documents required under 14 CFR §§ 91.9 and 91.203 must be available to the 

PIC at the Ground Control Station of the UAS any time the aircraft is operating. 

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

official upon request.

24. The UA must remain clear and give way to all manned aviation operations and 

activities at all times. 

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

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

persons, vessels, vehicles, and structures unless:

a. Barriers or structures are present that sufficiently protect nonparticipating persons 

from the UA and/or debris in the event of an accident. The operator must ensure 

that nonparticipating persons remain under such protection. If a situation arises 

where nonparticipating persons leave such protection and are within 500 feet of 

the UA, flight operations must cease immediately in a manner ensuring the safety 

of nonparticipating persons; and

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

for operating closer to those objects and the PIC has made a safety assessment of 

the risk of operating closer to those objects and determined that it does not 

present an undue hazard.

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

nonparticipating persons under this exemption.

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

permission from the property owner/controller or authorized representative. 

Permission from property owner/controller or authorized representative will be 

obtained for each flight to be conducted.

28. Any incident, accident, or flight operation that transgresses the lateral or vertical 

boundaries of the operational area as defined by the applicable COA must be reported 

to the FAA's UAS Integration Office (AFS−80) within 24 hours. Accidents must be 

reported to the National Transportation Safety Board (NTSB) per instructions 

contained on the NTSB Web site: www.ntsb.gov.

If this exemption permits operations for the purpose of closed-set motion picture and 

television filming and production, the following additional conditions and limitations apply.
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29. The operator must have a motion picture and television operations manual (MPTOM) 

as documented in this grant of exemption.

30. At least 3 days before aerial filming, the operator of the UAS affected by this 

exemption must submit a written Plan of Activities to the local Flight Standards 

District Office (FSDO) with jurisdiction over the area of proposed filming. The 3-day 

notification may be waived with the concurrence of the FSDO. The plan of activities 

must include at least the following:

a. Dates and times for all flights;

b. Name and phone number of the operator for the UAS aerial filming conducted 

under this grant of exemption;

c. Name and phone number of the person responsible for the on-scene operation of 

the UAS;

d. Make, model, and serial or N−Number of UAS to be used;

e. Name and certificate number of UAS PICs involved in the aerial filming;

f. A statement that the operator has obtained permission from property owners 

and/or local officials to conduct the filming production event; the list of those 

who gave permission must be made available to the inspector upon request;

g. Signature of exemption holder or representative; and

h. A description of the flight activity, including maps or diagrams of any area, city, 

town, county, and/or state over which filming will be conducted and the altitudes 

essential to accomplish the operation.

31. Flight operations may be conducted closer than 500 feet from participating persons 

consenting to be involved and necessary for the filming production, as specified in the 

exemption holder’s MPTOM.

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

operations must comply with all applicable parts of 14 CFR including, but not limited to, 

parts 45, 47, 61, and 91.
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This exemption terminates on June 30, 2017, unless sooner superseded or rescinded.

Sincerely,

/s/

John S. Duncan

Director, Flight Standards Service

Enclosures
UNITED STATES OF AMERICA

DEPARTMENT OF TRANSPORTATION

FEDERAL AVIATION ADMINISTRATION

WASHINGTON, DC 

Regulatory Docket No. _______________

IN THE MATTER OF THE PETITION FOR EXEMPTION OF:

RS&H, INC.

FOR AN EXEMPTION SEEKING RELIEF FROM THE REQUIREMENTS OF

TITLE 14 OF THE CODE OF FEDERAL REGULATIONS

SECTIONS 61.23(a) & (c), 61.101(e)(4) & (e)(5), 61.113(a), 61.315(a), 91.7(a), 91.119(c), 

91.121, 91.151(a)(1), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), AND 91.417(a) & (b)

CONCERNING COMMERCIAL OPERATION OF THE

DJI INSPIRE 1 UNMANNED AIRCRAFT SYSTEM

PURSUANT TO SECTION 333 OF

THE FAA MODERNIZATION AND REFORM ACT OF 2012 (PUBLIC LAW 112-95)

Submitted on April 03, 2015

GREGORY S. WINTON, ESQ.

THE AVIATION LAW FIRM

1997 Annapolis Exchange Parkway

Suite 300

Annapolis, Maryland 21401

Tel: (301) 294-8550

Fax: (866) 568-9886

Attorney for Petitioner
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TABLE OF CONTENTS

Page

GLOSSARY OF ABBREVIATIONS .................................................................................3

SUMMARY.........................................................................................................................4

INTRODUCTION AND INTERESTS OF PETITIONER .................................................4

BACKGROUND .................................................................................................................4

BASIS FOR THE PETITION..............................................................................................5

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

THE SPECIFIC SECTIONS OF 14 C.F.R. FROM WHICH RS&H SEEKS

EXEMPTION ................................................................................................................8

THE EXTENT OF RELIEF RS&H SEEKS AND THE REASON RS&H SEEKS 

THE RELIEF ...............................................................................................................14

THE REASONS WHY GRANTING RS&H'S REQUEST WOULD BE IN THE 

PUBLIC INTEREST ...................................................................................................20

THE REASONS WHY GRANTING THE EXEMPTION WOULD NOT 

ADVERSELY AFFECT SAFETY..............................................................................24

SUMMARY THAT CAN BE PUBLISHED IN THE FEDERAL REGISTER..........41

ANY ADDITIONAL INFORMATION, VIEWS, OR ARGUMENTS AVAILABLE 

TO SUPPORT RS&H'S REQUEST............................................................................41

CONCLUSION.................................................................................................................42
3

GLOSSARY OF ABBREVIATIONS

AGL Above Ground Level

AOI Area of Interest

ATC Air Traffic Control

ATO Air Traffic Organization

C.F.R. Code of Federal Regulations

COA Certificate of Authorization

FAA Federal Aviation Administration

FAR Federal Aviation Regulation

FCC Federal Communications Commission

GCS Ground Control Station

GPS Global Positioning System

NAS National Airspace System

NOTAM Notice to Airmen

OEM Original Equipment Manufacturer 

PIC Pilot In Command

RTH Return To Home

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

UA Unmanned Aircraft

UAS Unmanned Aircraft System

VFR Visual Flight Rules

VLOS Visual Line of Sight

VMC Visual Meteorological Conditions

VO Visual Observer

VTOL Vertical Takeoff and Landing 
4

SUMMARY

RS&H, Inc. seeks exemption from the requirements of 14 C.F.R. §§ 61.23(a) & (c), 

61.101(e)(4) & (e)(5), 61.113(a), 61.315(a), 91.7(a), 91.119(c), 91.121, 91.151(a)(1), 91.405(a), 

91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b), to operate an Unmanned Aircraft 

System pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA). 

This exemption will permit RS&H to operate an Unmanned Aircraft System (UAS) for the 

commercial purpose of conducting aerial acquisitions within the National Airspace System 

(NAS).

INTRODUCTION AND INTERESTS OF THE PETITIONER

RS&H, Inc. is an employee owned architecture, engineering, and consulting firm 

employing more than 850 associates. With a tradition that began in 1941, RS&H, Inc. has 

helped pioneers build the launch platforms for the national space program, create global airports 

that connect communities, shape progressive highway systems across the country, and provide 

facilities for Fortune 1000 companies. RS&H, Inc. is headquartered in Jacksonville, Florida, and 

primarily provides services to Aerospace, Aviation, Corporate, Defense, Health & Science, and 

Transportation clients. RS&H, Inc. is consistently ranked among the nation’s top 100 design 

firms, operates more than 36 offices, and has worked in over 50 countries across the globe.

RS&H, Inc. will utilize the DJI Inspire 1 to commercially provide professional geospatial 

data collection, aerial photography, infrastructure inspection services, and disaster area damage 

and debris assessments to our clients. Use of the DJI Inspire 1 will provide RS&H, Inc. a safe 

and efficient platform to perform its business operations.

BACKGROUND

Unmanned Aircraft System: DJI Inspire 1
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RS&H, Inc. (hereinafter referred to as “RS&H”) seeks an exemption to operate the DJI 

Inspire 1 UAS (Inspire 1 UAS) for compensation or hire within the NAS. The Inspire 1 UAS is

comprised of a vertical takeoff and landing (VTOL) Unmanned Aircraft (UA) and a Remote 

Controller capable of connecting to a Mobile Device. The Inspire 1 UA has a maximum gross 

weight, with payload, of approximately 7.5 pounds; the Inspire 1 UA measures approximately 

17.2 in. x 17.8 in. x 11.9 in.; and has a maximum speed of approximately 42.8 knots. The 

Inspire 1 UA is equipped with four rotors mounted in a quad-copter configuration, each driven 

by a Lithium Polymer battery powered electric motor.

The Inspire 1 UA that will be operated by RS&H will both 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 THE PETITION

RS&H, by and through undersigned counsel, pursuant to the provisions of the Federal 

Aviation Regulations (14 C.F.R. § 11.61) and the FAA Modernization and Reform Act of 2012, 

Section 333, Special Rules for Certain Unmanned Aircraft Systems, hereby petitions the 

Administrator to operate the Inspire 1 UAS within the National Airspace System (NAS), and for 

an exemption from the requirements of 14 C.F.R. §§ 61.23(a) & (c), 61.101(e)(4) & (e)(5), 

61.113(a), 61.315(a), 91.7(a), 91.119(c), 91.121, 91.151(a)(1), 91.405(a), 91.407(a)(1), 

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

In consideration of the size, weight, speed, and limited operating area associated with the 

unmanned aircraft and its operation, RS&H’s operation of the Inspire 1 UAS meets the 
6

conditions of FMRA Section 333 and therefore, will not require an airworthiness certificate in 

accordance with 14 C.F.R. Part 21, Subpart H. 

Accordingly, RS&H 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. 

RS&H submits that the requested relief is proper since an equivalent level of safety will 

be ensured. All maintenance, alterations, and preventive maintenance of the Inspire 1 UAS

performed by RS&H will be in accordance with the methods, techniques, and practices 

prescribed in the operating documents (i.e., Inspire 1 User Manual, Inspire 1 Quick Start Guide, 

Inspire 1 1345 Propeller Locks Quick Start Guide, Inspire 1 Intelligent Flight Battery Safety 

Guidelines, Inspire 1 Safety Guidelines, and Inspire 1 Maintenance Manual). Furthermore, only 

the Original Equipment Manufacturer (OEM) or qualified OEM maintainers will perform higher 

level inspections and maintenance per the operating documents and OEM standards. RS&H will 

document and maintain all maintenance records for the Inspire 1 UAS. 

Relief from certain requirements of Sections 61.23(a) & (c), entitled Medical certificates: 

Requirement and duration, 61.101(e)(4) & (e)(5), entitled Recreational pilot privileges and 

limitations; 61.113(a), entitled Private pilot privileges and limitations: Pilot in command; and 

61.315(a), entitled What are the privileges and limits of my sport pilot certificate, is requested by 

RS&H to the extent necessary to allow the proposed UAS flight operations to be conducted by a 

Pilot in Command (PIC) holding a sport pilot certificate, recreational pilot certificate, or private 

pilot certificate, as well as an FAA-issued medical certificate or U.S. issued driver’s license, and 

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

is able to safely operate the Inspire 1 UAS in a manner consistent with this exemption, including 
7

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

vehicles, and structures.

RS&H seeks relief from Section 91.7(a), entitled Civil aircraft airworthiness, because the 

Inspire 1 UAS does not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, 

Subpart H. As such, RS&H submits that it will ensure that the Inspire 1 UAS is in an airworthy 

condition, prior to every flight, by determining that the UAS being used is in compliance with its

operating documents (i.e., Inspire 1 User Manual, Inspire 1 Quick Start Guide, Inspire 1 1345 

Propeller Locks Quick Start Guide, Inspire 1 Intelligent Flight Battery Safety Guidelines, Inspire 

1 Safety Guidelines, and Inspire 1 Maintenance Manual), and that the aircraft is in a condition 

for safe flight.

 RS&H seeks relief from Section 91.119(c), entitled Minimum safe altitudes: (c) Over 

other than congested areas, because the Inspire 1 UAS will be flown at an altitude at or below

400 feet AGL, and to the extent that the Inspire 1 UAS may be operated closer than 500 feet 

from persons, vessels, vehicles, and structures under certain conditions.

RS&H also seeks an exemption from the requirements of Section 91.121, entitled 

Altimeter Settings, because the altitude reporting equipment of the Inspire 1 UAS is set to zero 

feet above ground level (AGL), rather than local barometric pressure or field altitude, before 

each flight. The altitude information of the Inspire 1 UA is provided to the PIC via a barometric 

pressure sensor, Global Positioning System (GPS) equipment, a Visual Positioning System using 

ultrasonic and image data, and a radio communications telemetry data link, which downlinks 

from the UA to the GCS for active monitoring of the flight path. A level of safety equivalent to 

Section 91.121 will be ensured, as the altitude of the Inspire 1 UA will be reported to air traffic 
8

control (ATC) in feet AGL, and RS&H will operate the Inspire 1 UA within visual line of sight, 

at or below 400 feet AGL.

Additionally, RS&H seeks an exemption from the requirements of Section 91.151(a)(1),

entitled Fuel requirements for flight in VFR conditions. RS&H submits that safety will not be 

affected by operation of the Inspire 1 UA during daylight hours in visual meteorological 

conditions (VMC) under visual flight rules (VFR), with enough battery power for the Inspire 1

UA to fly for a total duration of 13 minutes to the first point of intended landing and, assuming 

normal cruising speed, to fly after that for at least five (5) minutes (i.e., approximately 30 percent 

battery power remaining).

In accordance with 14 C.F.R. § 11.81, RS&H provides the following information in 

support of its petition for exemption:

A. Name And Address Of T he Petitioner.

The name and address of the Petitioner is:

RS&H, Inc.

10748 Deerwood Park Boulevard South

Jacksonville, Florida 32256

The point of contact for this Petition and specific contact information is as follows:

Gregory S. Winton, Esq.

The Aviation Law Firm

1997 Annapolis Exchange Parkway, Suite 300

Annapolis, Maryland 21401

Tel: (301) 294-8550 | Fax: (866) 568-9886

Email: Greg@aviationlawexperts.com

B. The Specific Sections Of 14 C.F.R. From Which RS&H Seeks Exemption.

1. RS&H Seeks Exemption From The Requirements Of Sections

61.23(a) & (c).

Section 61.23, entitled Medical certificates: Requirement and duration, subsections (a)
9

and (c) prescribe the following, in relevant part:

(a) Operations requiring a medical certificate. Except as provided in paragraphs (b) and 

(c) of this section, a person:

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

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

pilot certificate;

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

certificate in flag or supplemental operation in part 121 of this chapter that requires three 

or more pilots; or

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

conducted under part 121 of this chapter if the pilot has reached his or her 60th birthday.

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

(i) Second-in-command privileges of an airline transport pilot in part 121 of this 

chapter (other than operations specified in paragraph (a)(1)(ii) of this section); or

(ii) Privileges of a commercial pilot certificate; or

(3) Must hold at least a third-class medical certificate--

(i) When exercising the privileges of a private pilot certificate;

(ii) When exercising the privileges of a recreational pilot certificate;

(iii) When exercising the privileges of a student pilot certificate;

(iv) When exercising the privileges of a flight instructor certificate and acting as 

pilot in command;

.

(v) When exercising the privileges of a flight instructor certificate and serving as 

a required pilot flight crewmember;

(vi) When taking a practical test in an aircraft for a recreational pilot, private pilot, 

commercial pilot, or airline transport pilot certificate, or for a flight instructor certificate; 

or

(vii) When performing the duties as an Examiner in an aircraft when 

administering a practical test or proficiency check for an airman certificate, rating, or 

authorization.
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(c) Operations requiring either a medical certificate or U.S. driver’s license:

(1) A person must hold and possess either a medical certificate issued under part 

67 of this chapter or a U.S. driver’s license when:

(i) Exercising the privileges of a student pilot certificate while seeking sport pilot 

privileges in a light-sport aircraft other than a glider or balloon;

(ii) Exercising the privileges of a sport pilot certificate in a light-sport aircraft 

other than a glider or balloon;

(iii) Exercising the privileges of a flight instructor certificate with a sport pilot 

rating while acting as pilot in command or serving as a required flight crewmember of a 

light-sport aircraft other than a glider or balloon; or

(iv) Serving as an Examiner and administering a practical test for the issuance of a 

sport pilot certificate in a light-sport aircraft other than a glider or balloon.

(2) A person using a U.S. driver's license to meet the requirements of this 

paragraph must--

(i) Comply with each restriction and limitation imposed by that person's U.S. 

driver's license and any judicial or administrative order applying to the operation of a 

motor vehicle;

(ii) Have been found eligible for the issuance of at least a third- class airman 

medical certificate at the time of his or her most recent application (if the person has 

applied for a medical certificate);

(iii) Not have had his or her most recently issued medical certificate (if the person 

has held a medical certificate) suspended or revoked or most recent Authorization for a 

Special Issuance of a Medical Certificate withdrawn; and

(iv) Not know or have reason to know of any medical condition that would make 

that person unable to operate a light-sport aircraft in a safe manner.

2. RS&H Seeks Exemption From The Requirements Of Section 

61.101(e)(4) & (e)(5).

Sections 61.101, entitled Recreational pilot privileges and limitations, subsections (e)(4) 

and (e)(5) prescribe the following in relevant part:

(e) Except as provided in paragraphs (d) and (i) of this section, a recreational pilot may 

not act as pilot in command of an aircraft--
11

(4) For compensation or hire;

(5) In furtherance of a business;

3. RS&H Seeks Exemption From The Requirements Of Section

61.113(a).

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

subsection (a) prescribes 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.

4. RS&H Seeks Exemption From The Requirements Of Section 

61.315(a).

Section 61.315, entitled What are the privileges and limits of my sport pilot certificate, 

subsection (a) prescribes the following in part:

(a) If you hold a sport pilot certificate you may act as pilot in command of a light-sport 

aircraft, except as specified in paragraph (c) of this section.

5. RS&H 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.

6. RS&H Seeks Exemption From The Requirements Of Section 

91.119(c).

Section 91.119(c), entitled Minimum safe altitudes: (c) Over other than congested areas, 

states the following, in part:

Except when necessary for takeoff or landing, no person may operate an aircraft below 

the following altitudes:

(c) Over other than congested areas. An altitude of 500 feet above the surface, except 

over open water or sparsely populated areas. In those cases, the aircraft may not be 

operated closer than 500 feet to any person, vessel, vehicle, or structure.

7. RS&H Seeks Exemption From The Requirements Of Section 91.121.
12

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. RS&H Seeks Exemption From The Requirements Of Section

91.151(a)(1).

Section 91.151, entitled Fuel requirements for flight in VFR conditions, subsection (a)(1), 

states the following, in relevant part:

(a) No person may begin a flight in an airplane 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--

(1) During the day, to fly after that for at least 30 minutes;

9. RS&H 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[.]

10. RS&H Seeks Exemption From The Requirements Of Section 91.407(a)(1).
13

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[.]

11. RS&H 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.

12. RS&H 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
14

(iii) The signature, and certificate number of the person approving the 

aircraft for return to service.

(2) Records containing the following information:

(i) The total time in service of the airframe, each engine, each propeller, 

and each rotor.

(ii) The current status of life-limited parts of each airframe, engine, 

propeller, rotor, and appliance.

(iii) The time since last overhaul of all items installed on the aircraft which 

are required to be overhauled on a specified time basis.

(iv) The current inspection status of the aircraft, including the time since 

the last inspection required by the inspection program under which the aircraft 

and its appliances are maintained.

(v) The current status of applicable airworthiness directives (AD) and 

safety directives including, for each, the method of compliance, the AD or safety 

directive number and revision date. If the AD or safety directive involves 

recurring action, the time and date when the next action is required.

(vi) Copies of the forms prescribed by § 43.9(d) of this chapter for each 

major alteration to the airframe and currently installed engines, rotors, propellers, 

and appliances.

(b) The owner or operator shall retain the following records for the periods prescribed:

(1) The records specified in paragraph (a)(1) of this section shall be retained until 

the work is repeated or superseded by other work or for 1 year after the work is 

performed.

(2) The records specified in paragraph (a)(2) of this section shall be retained and 

transferred with the aircraft at the time the aircraft is sold.

(3) A list of defects furnished to a registered owner or operator under § 43.11 of 

this chapter shall be retained until the defects are repaired and the aircraft is approved for 

return to service.

C. The Extent Of Relief RS&H Seeks And The Reason RS&H Seeks The Relief.

1. Extent of Relief RS&H Seeks And The Reason RS&H Seeks Relief From 

Section 61.23(a) & (c).
15

Relief from Sections 61.23(a) & (c) entitled Medical certificates: Requirement and 

duration, is requested to the extent necessary to allow an adequately certificated PIC holding an 

FAA-issued medical certificate or U.S. issued driver’s license, to conduct the proposed UAS 

flight operations for compensation or hire.

This relief is requested since the limitations set forth in Section 61.23(a) state that the 

holder of a recreational pilot, private pilot, commercial pilot, or airline transport pilot certificate, 

or flight instructor certificate must also hold the appropriate FAA-issued medical certificate to 

exercise the privileges of the pilot certificate. The relief is further requested since the limitations 

set forth in Section 61.23(c) state that the holder of a sport pilot certificate must also hold a U.S. 

issued driver’s license when exercising the privileges of the certificate in a light sport aircraft.

As set forth more fully below, RS&H submits that an equivalent level of safety will be 

maintained because no PIC will be allowed to operate the Inspire 1 UAS unless that PIC has met 

certain flight-hour and currency requirements, demonstrating that the PIC is able to safely 

operate the Inspire 1 UAS in a manner consistent with the operations specifications as set forth 

herein, including evasive and emergency maneuvers, as well as maintaining appropriate 

distances from people, vessels, vehicles, and structures. Additionally, RS&H will require that a 

PIC operating the Insipre 1 UAS pursuant to this Petition hold at least a U.S. issued driver’s 

license, the minimum requirement to act as PIC of a light sport aircraft.

2. Extent of Relief RS&H Seeks And The Reason RS&H Seeks Relief From 

Sections 61.101(e)(4) & (e)(5), 61.113(a), and 61.315(a).

Relief from Sections 61.101(e)(4) & (e)(5), entitled Recreational pilot privileges and

limitations; Section 61.113(a), entitled Private pilot privileges and limitations: Pilot in 

command; and Section 61.315(a), entitled What are the privileges and limits of my sport pilot 

certificate, is requested to the extent necessary to allow a PIC holding a sport pilot, recreational 
16

pilot, or private pilot certificate, as well as an airman medical certificate or U.S. issued driver’s 

license, and who has met certain flight-hour and currency requirements, to conduct the proposed 

UAS flight operations for compensation or hire, subject to the conditions and limitations below.

This relief is requested since the limitations set forth in Sections 61.101(e)(4) & (e)(5) 

state that no person who holds a recreational pilot certificate may act as pilot in command of an 

aircraft for compensation or hire or in furtherance of a business. Relief is requested from 

61.113(a) since the limitations set forth in that section state that no person who holds a private 

pilot certificate may act as pilot in command of an aircraft that is carrying passengers or property 

for compensation or hire; nor may that person, for compensation or hire, act as pilot in command 

of an aircraft. Relief is requested from 61.315(a) since the limitations set forth in that section

only allow a person who holds a sport pilot certificate to act as pilot in command of a light-sport 

aircraft.

As set forth more fully below, RS&H submits that an equivalent level of safety will be 

maintained because no PIC will be allowed to operate the Inspire 1 UAS unless that PIC has met 

certain flight-hour and currency requirements, demonstrating that the PIC is able to safely 

operate the Inspire 1 UAS in a manner consistent with the operations specifications as set forth 

herein, including evasive and emergency maneuvers, as well as maintaining appropriate 

distances from people, vessels, vehicles, and structures.

Further, RS&H submits that the additional airmanship experience of a commercially

certified pilot would not correlate to the airmanship skills necessary for RS&H’s specific 

proposed operations.

2. Extent of Relief RS&H Seeks And The Reason RS&H Seeks Relief From 

Section 91.7(a).
17

Relief from Section 91.7(a) entitled Civil aircraft airworthiness, is requested to the extent 

required to allow RS&H to determine that the Inspire 1 UAS is in an airworthy condition prior to 

every flight by ensuring that the UAS is in compliance with its operating documents (i.e., Inspire 

1 User Manual, Inspire 1 Quick Start Guide, Inspire 1 1345 Propeller Locks Quick Start Guide, 

Inspire 1 Intelligent Flight Battery Safety Guidelines, Inspire 1 Safety Guidelines, and Inspire 1 

Maintenance Manual).

RS&H seeks the requested relief because the Inspire 1 UAS does not require an 

airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. Therefore, RS&H will 

ensure that the Inspire 1 UAS is in an airworthy condition based upon their compliance with the 

relevant operating documents prior to every flight, and further, determine the aircraft is in a 

condition for safe flight, as stated in the conditions and limitations below.

3. Extent of Relief RS&H Seeks And The Reason RS&H Seeks Relief From 

Section 91.119(c).

Relief from Section 91.119(c), entitled Minimum safe altitudes: (c) Over other than 

congested areas, is required because all proposed operations of the Inspire 1 UAS will take place 

at an altitude at or below 400 feet AGL. This relief is requested since the limitations set forth in 

Section 91.119(c) state that no person may operate an aircraft below 500 feet above the surface. 

As set forth more fully below, RS&H submits that a level of safety equivalent to Section 

91.119(c) will be maintained because operations will be conducted in areas with controlled 

access and under the safety provisions contained within this petition and the Inspire 1 operating 

documents.

Additionally, relief from Section 91.119(c) is requested to the extent necessary to allow 

operations to be conducted closer than 500 feet to persons, vessels, vehicles, or structures, under 

certain conditions. This relief is requested since the limitations set forth in Section 91.119(c)
18

prohibit operating an aircraft closer than 500 feet to a person, vessel, vehicle, or structure. As set 

forth more fully below, RS&H submits an equivalent level of safety will be maintained because 

operations closer than 500 feet to a person, vessel, vehicle, or structure will first require that the 

operator receive permission from any nonparticipating persons or the person who owns/controls 

the property. In addition, barriers or structures will be in place to sufficiently protect 

nonparticipating persons from debris in the event of an accident and all nonparticipating persons 

will be required to remain under such protections for the duration of the operation.

4. Extent Of Relief RS&H Seeks And The Reason RS&H Seeks Relief From 

Section 91.121.

Relief from Section 91.121, entitled Altimeter settings, may be required to allow flight 

operations of the Inspire 1 UAS, because the Inspire 1 UA’s altitude reporting equipment may be 

set on the ground to zero feet AGL, rather than local barometric pressure or field altitude, before 

each flight. The Inspire 1 UAS utilizes a barometric pressure sensor, GPS equipment, a Visual 

Positioning System using ultrasonic and imaging data, and a radio communications telemetry 

data link to downlink altitude information from the UA to the PIC at the Remote Controller. 

Considering the limited altitude of the proposed operations, relief from 14 C.F.R. § 

91.121 is sought to the extent necessary to comply with the applicable conditions and limitations 

stated below. As more fully set forth herein, a level of safety equivalent to Section 91.121 will 

be ensured as the altitude of the Inspire 1 UA will be reported to air traffic control (ATC) in feet 

above ground level (AGL), and RS&H will operate the Inspire 1 UA within visual line of sight, 

at or below 400 feet AGL.

5. Extent Of Relief RS&H Seeks And The Reason RS&H Seeks Relief From 

Section 91.151(a)(1).
19

Relief from Section 91.151(a)(1) entitled Fuel requirements for flight in VFR conditions, 

is requested to the extent required to allow flights of the battery powered Inspire 1 UA during 

daylight hours in visual meteorological conditions (VMC), under visual flight rules (VFR) for 

the Inspire 1 UA to fly for a total duration of 13 minutes to the first point of intended landing 

and, assuming normal cruising speed, to fly after that for at least five (5) minutes (i.e., 

approximately 30 percent battery power remaining). RS&H seeks the requested relief because

without an exemption from Section 91.151(a)(1), the flight time duration of the battery powered

Inspire 1 UA will severely constrain the practicality of any aerial acquisition and research flight 

operations that RS&H proposes to conduct pursuant to this Petition.

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

Inspire 1 UAS operating documents, and RS&H’s proposed operating limitations, ensure that

RS&H will safely operate the battery powered Inspire 1 UA during daylight hours in visual 

meteorological conditions (VMC) under visual flight rules (VFR), with enough battery power for 

the Inspire 1 UA to fly for a total duration of 13 minutes to the first point of intended landing 

and, assuming normal cruising speed, to fly after that for at least five (5) minutes (i.e., 

approximately 30 percent battery power remaining).

6. Extent Of Relief RS&H Seeks And The Reason RS&H 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, RS&H requests relief from these Sections 

because the Inspire 1 UAS does not require an airworthiness certificate. As set forth more fully

below, the Inspire 1 UAS meets the conditions of Section 333 of the FMRA for operation 

without an airworthiness certificate. 
20

All maintenance, alterations, and preventive maintenance on the UAS of the Inspire 1

UAS performed by RS&H will be in accordance with the methods, techniques, and practices 

prescribed in the operating documents (i.e., Inspire 1 User Manual, Inspire 1 Quick Start Guide, 

Inspire 1 1345 Propeller Locks Quick Start Guide, Inspire 1 Intelligent Flight Battery Safety 

Guidelines, Inspire 1 Safety Guidelines, and Inspire 1 Maintenance Manual). Furthermore, only 

the Original Equipment Manufacturer (OEM) or qualified OEM maintainers will perform higher 

level inspections and maintenance per the operating documents and OEM standards. RS&H will 

document and maintain all maintenance records for the Inspire 1 UAS. 

D. The Reasons Why Granting RS&H’s 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 RS&H to safely, 

efficiently, and economically perform aerial acquisitions and research within the NAS, 

commercially, in support of the aerospace, aviation, corporate, defense, government, health & 

science, and transportation industries. Additionally, use of the Inspire 1 UAS will decrease 

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

Notably, the benefits of RS&H’s proposed operation of the Inspire 1 UAS will be realized 

without implicating any privacy issues. 

1. The Public Will Benefit From The Aerial Acquisition And Research 

Performed.

RS&H submits this Petition to commercially operate the Inspire 1 UAS and perform 

aerial acquisitions, such as geospatial data collection, aerial photography, and infrastructure 

inspection, within the NAS, in support of the aerospace, aviation, corporate, defense, 

government, health & science, and transportation industries. The Inspire 1 UAS will provide 
21

safe, efficient, and economical aerial acquisition and research operations to further each of these 

fields, all of which are critical to the well-being of the general public. 

Operations that RS&H will perform with the Inspire 1 UAS highlight how the requested 

exemption will directly benefit the above-referenced industries and the public, as a whole. For 

example, by conducting disaster area damage and debris assessments, the precision aerial 

acquisitions performed by the UAS will be used to benefit the public interest and increase safety 

for workers and the general public by identifying potential hazards and conducting damage 

assessments before recovery personnel are committed to areas requiring relief. The use of the 

Inspire 1 UAS would greatly increase the safety and efficiency of recovery and cleanup efforts 

surrounding disasters, greatly benefitting the communities requiring aid.

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

The Inspire 1 UA is battery powered and serves as a safe, efficient, and economical 

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

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

of the Inspire 1 UAS would reduce the amount of manned aircraft in the NAS, reduce noise and 

air pollution, and 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 Inspire 

1 UA does not require an airport to takeoff or land. Likewise, a reduction of manned aircraft 

conducting aerial survey missions would result in fewer aircraft that must be handled by air 

traffic control during the ground, takeoff, departure, arrival, and landing phases of flight 

operations. 

3. The Public Will Benefit From The Safety And Efficiency Of The Inspire 1

UAS.
22

Conducting aerial acquisitions with the 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 survey flight operations. By using battery power and an electric motor, the 

Inspire 1 UAS produces no air pollution, and is the most viable environmentally conscious 

alternative to the cabin class, six cylinder internal combustion twin engine aircraft that are 

typically utilized for aerial acquisitions, and burn approximately 20-30 gallons per hour of leaded 

aviation fuel. The Inspire 1 UA, while reducing the carbon footprint of aerial acquisitions, also 

reduces noise pollution, as the UA is propelled by battery powered electric motors, rather than

internal combustion engines.

By using the 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 

flightcrew members located onboard the aircraft, the Inspire 1 UA (weighing approximately 7.5

pounds at maximum gross weight; measuring 17.2 in. x 17.8 in. x 11.9 in.; and carrying 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 aerial acquisitions (weighing 

approximately 6,500 pounds with a wingspan of approximately 40 feet, a length of 34 feet, and a 

fuel capacity of 180 gallons).

Additionally, using the Inspire 1 UAS to perform aerial acquisitions will increase the 

level of safety and efficiency for RS&H’s employees, associated contractors, and public 

employees by minimizing exposure to a number of hazards typically encountered in a field 

environment, such as bridges, wetland areas, and steep terrain, as well as lowering the number of 
23

incidents and associated costs, such as maintaining a certain level of insurance, that normally 

coincide with operations in a hazardous field environment. 

4. Performing Aerial Acquisition Operations With The Inspire 1 UAS Will 

Benefit The Economy. 

In addition to being safe and efficient, the Inspire 1 UAS is also an economical 

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

Inspire 1 UAS will allow United States based companies, like RS&H, 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. Operation of a UAS such as the battery powered Inspire 1 UAS is one such 

technology that not only allows companies greater operational flexibility compared to manned 

aircraft, but provides such flexibility without the high operational cost of a traditional manned 

aircraft. 

By operating the Inspire 1 UAS, companies such as RS&H, 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 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. 

5. There Are No Privacy Issues.

Similar to the manned aerial acquisition flight operations that have been conducted for 

decades, RS&H’s proposed operation of the Inspire 1 UAS will not implicate any privacy issues. 
24

Specifically, the Inspire 1 UAS will only be operated pursuant to the specific conditions and 

limitations set forth herein, and in accordance with the Federal Aviation Regulations, including 

the minimum altitude requirements of 14 C.F.R. § 91.119. Most significantly, the Inspire 1 UA 

will not be operated closer than 500 feet to any person, vessel, vehicle, or structure, which is not 

directly involved in the operation unless specific conditions are met.

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 RS&H Seeks Exemption.

1. Reasons Why The Inspire 1 UAS Meets The Conditions Of The FAA 

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

In consideration of the size, weight, speed, and limited operating area associated with the 

unmanned aircraft and its operation, RS&H’s operation of the Inspire 1 UAS meets the 

conditions of FMRA Section 333, and will not require an airworthiness certificate in accordance 

with 14 C.F.R. Part 21, Subpart H. 

Section 333 provides authority for a UAS to operate without airworthiness certification

and sets forth requirements for considering whether a UAS will create a hazard to users of the 

NAS or the public, or otherwise pose a threat to national security. Specifically, FMRA Section 

333 states the following, in part:

(a) In General.--Notwithstanding any other requirement of this subtitle, and not later 

than 180 days after the date of enactment of this Act, the Secretary of Transportation 

shall determine if certain unmanned aircraft systems may operate safely in the national 

airspace system before completion of the plan and rulemaking required by section 332 of 

this Act or the guidance required by section 334 of this Act.

(b) Assessment of Unmanned Aircraft Systems.--In making the determination under 

subsection (a), the Secretary shall determine, at a minimum--

(1) which types of unmanned aircraft systems, if any, as a result of their size, 

weight, speed, operational capability, proximity to airports and populated areas, 

and operation within visual line of sight do not create a hazard to users of the 

national airspace system or the public or pose a threat to national security; and
25

(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, RS&H submits that Inspire 1 UAS can operate safely in the 

NAS pursuant to FMRA Section 333, as demonstrated by: (a) the characteristics of the Inspire 1

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

a. The Specifications Of The Inspire 1 UAS Demonstrate Its Safe 

Characteristics. 

The Inspire 1 UAS does not create a hazard to users of the NAS or the public, or 

otherwise pose a threat to national security considering its size, weight, speed, and operational 

capability. 

i. Technical Specifications Of The Inspire 1 UAS.

The technical specifications of the Inspire 1 UAS are set forth at pages 57 through 59 of

the Inspire 1 User Manual, attached hereto as Exhibit A. Exhibit A contains proprietary 

information and is to be held in a separate file pursuant to 14 C.F.R. § 11.35(b)1.

ii. The Inspire 1 UAS’s Autonomous Flight And Navigation

Modes Enable It To Remain Within A Defined Operational 

Area.

The Inspire 1 UAS is enabled to enter autonomous flight under certain contingency 

situations or at the command of the Remote Controller. The Inspire 1 UAS autonomous features 

include the following: a GPS Position and Altitude Hold when initiated by the Remote 

 

1 Exhibits to this Petition contain proprietary information, and in accordance with 14 C.F.R. § 

11.35(b), are not to be included in the Federal Docket Management System (FDMS).
26

Controller; a Return To Home (RTH) function; and Flight Limits (i.e, pre-set limitations that 

restrict the distance and height of the UAS flight operations). 

A complete description of the autonomous modes of the Inspire 1 UAS is provided at 

pages 12 through 17 and pages 45 through 48 of the Inspire 1 User Manual, attached hereto as 

Exhibit A. Exhibit A contains proprietary information and is to be held in a separate file 

pursuant to 14C.F.R. § 11.35(b).

iii. The Inspire 1 UAS Is Designed For Automatic Return To

Home Point Or Auto-Land In The Event Of Loss Of The 

Control Link Or Navigation.

A complete description of the Failsafe Functions of the Inspire 1 UAS is set forth at

pages 12 through 17 and pages 45 through 48 of the Inspire 1 User Manual, attached hereto as 

Exhibit A. Exhibit A contains proprietary information and is to be held in a separate file 

pursuant to 14 C.F.R. § 11.35(b).

iv. The Inspire 1 UAS Remote Controller And Its Operation.

A complete description of the operation and specifications of the Inspire 1 UAS Remote 

Controller and its software is provided at pages 24 through 33 of the Inspire 1 User Manual. The 

Inspire 1 UAS is compliant with all Federal Communications Commission (FCC) requirements, 

and the radio frequency spectrum used for operation and control of the UA is set forth at page 58

of the Inspire 1 User Manual. A copy of the Inspire 1 User Manual, which contains proprietary 

information, is attached hereto as Exhibit A, and is to be held in a separate file pursuant to 14 

C.F.R. § 11.35(b).

b. Flight Operations Of The Inspire 1 UAS Are Limited To The Line Of 

Sight Of A Certificated Pilot in Command With A Safety Observer.

RS&H will only utilize certificated pilots who possess a current and valid FAA issued 

airman medical certificate or valid U.S. issued driver’s license to act as a pilot in command (PIC)
27

of the Inspire 1 UAS. Additionally, a safety observer will assist all pilots during flight 

operations.

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

Operating Limitations.

In seeking this exemption, RS&H proposes to commercially operate the Inspire 1 UAS 

for the special purpose of conducting aerial acquisitions within the NAS, pursuant to the 

following specific operating limitations:

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

Unmanned Aircraft System when weighing less than 55 pounds including payload. 

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

amend this grant. 

2. Operations for the purpose of closed-set motion picture and television filming are not 

permitted.

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

exemption holder may use either groundspeed or calibrated airspeed to determine 

compliance with the 87 knot speed restriction. In no case will the UA be operated at 

airspeeds greater than the maximum UA operating airspeed recommended by the aircraft 

manufacturer.

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

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

5. The UA must be operated within visual line of sight (VLOS) of the PIC at all times. 

This requires the PIC to be able to use human vision unaided by any device other than 

corrective lenses, as specified on the PIC’s FAA-issued airman medical certificate or 

U.S. driver’s license. 

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

the visual line of sight (VLOS) of the PIC and VO at all times. The VO may be used to 

satisfy the VLOS requirement as long as the PIC always maintains VLOS capability. The 

VO and PIC must be able to communicate verbally at all times. Electronic messaging or 

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

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

must also ensure that the VO can perform the duties required of the VO.

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

operations in accordance with the conditions and limitations stated in this grant of 

exemption, are hereinafter referred to as the operating documents. The operating 
28

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

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

limitations in this exemption and the procedures outlined in the operating documents, the 

conditions and limitations herein take precedence and must be followed. Otherwise, the 

operator must follow the procedures as outlined in its operating documents. The operator 

may update or revise its operating documents. It is the operator’s responsibility to track 

such revisions and present updated and revised documents to the Administrator or any 

law enforcement official upon request. The operator must also present updated and 

revised documents if it petitions for extension or amendment to this grant of exemption. 

If the operator determines that any update or revision would affect the basis upon which 

the FAA granted this exemption, then the operator must petition for an amendment to its 

grant of exemption. The FAA’s UAS Integration Office (AFS-80) may be contacted if 

questions arise regarding updates or revisions to the operating documents.

8. Any UAS that has undergone maintenance or alterations that affect the UAS operation 

or flight characteristics, e.g. replacement of a flight critical component, must undergo a 

functional flight test prior to conducting further operations under this exemption. 

Functional test flights may only be conducted by a PIC with a VO and must remain at 

least 500 feet from other people. The functional test flight must be conducted in such a 

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

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

in a condition for safe operation.

10. Prior to each flight, the PIC must conduct a pre-flight inspection and determine the 

UAS is in a condition for safe flight. The pre-flight inspection must account for all 

potential discrepancies, e.g. inoperable components, items, or equipment. If the 

inspection reveals a condition that affects the safe operation of the UAS, the aircraft is 

prohibited from operating until the necessary maintenance has been performed and the 

UAS is found to be in a condition for safe flight.

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

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

components. 

12. Each UAS operated under this exemption must comply with the manufacturer safety 

bulletins. 

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

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

current FAA airman medical certificate or a valid U.S. driver’s license issued by a state, 

the District of Columbia, Puerto Rico, a territory, a possession, or the Federal 

government. The PIC must also meet the flight review requirements specified in 14 CFR 

§ 61.56 in an aircraft in which the PIC is rated on his or her pilot certificate.
29

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

ability to safely operate the UAS in a manner consistent with how the UAS will be 

operated under this exemption, including evasive and emergency maneuvers and 

maintaining appropriate distances from persons, vessels, vehicles and structures. PIC 

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

CFR § 61.51(b). Flights for the purposes of training the operator’s PICs and VOs 

(training, proficiency, and experience-building) and determining the PIC’s ability to 

safely operate the UAS in a manner consistent with how the UAS will be operated under 

this exemption are permitted under the terms of this exemption. However, training 

operations may only be conducted during dedicated training sessions. During training, 

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

are considered nonparticipants in accordance with 14 CFR § 91.119.

15. 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). Flights 

under special visual flight rules (SVFR) are not authorized. 

16. The UA may not operate within 5 nautical miles of an airport reference point (ARP) 

as denoted on a current FAA Airport/Facility Directory (AFD) or for airports not denoted 

with an ARP, the center of the airport symbol as denoted on the current FAA-published 

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

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

agreement with the airport management must be made available to the Administrator or 

any law enforcement official upon request. 

17. The UA may not be operated less than 500 feet below or less than 2,000 feet 

horizontally from a cloud or when visibility is less than 3 statute miles from the PIC. 

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

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

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

weather conditions) there is enough power for the UA to conduct the intended operation 

and to operate after that for at least five minutes or within the reserve power 

recommended by the manufacturer if greater. 

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

operations shall be conducted in accordance with an ATO-issued COA. The exemption 

holder may apply for a new or amended COA if it intends to conduct operations that 

cannot be conducted under the terms of the attached COA.

22. All aircraft operated in accordance with the exemption must be identified by serial 

number, registered in accordance with 14 C.F.R. part 47, and have identification (N-
30

Number) markings in accordance with 14 C.F.R. part 45, Subpart C. Markings must be as 

large as practicable. 

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

and any documents required under 14 CFR §§91.9 and 91.203 must be available to the 

PIC at the Ground Control Station of the UAS any time the aircraft is operating. These 

documents must be made available to the Administrator or any law enforcement official 

upon request.

24. The UA must remain clear and give way to all manned aviation operations and 

activities at all times.

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

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

persons, vessels, vehicles, and structures unless:

a. Barriers or structures are present that sufficiently protect nonparticipating 

persons from the UA and/or debris in the event of an accident. The operator must 

ensure that nonparticipating persons remain under such protection. If a situation

arises where nonparticipating persons leave such protection and are within 500 

feet of the UA, flight operations must cease immediately in a manner ensuring the 

safety of nonparticipating persons; and,

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

permission for operating closer to those objects and the PIC has made a safety 

assessment of the risk of operating closer to those objects and determined that it 

does not present an undue hazard.

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

nonparticipating persons under this exemption.

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

permission from the property owner/controller or authorized representative. Permission 

from the land owner/controller or authorized representative will be obtained for each 

flight to be conducted. 

28. Any incident, accident, or flight operation that transgresses the lateral or vertical 

boundaries of the operational area as defined by the applicable COA must be reported to 

the FAA's UAS Integration Office (AFS-80) within 24 hours. Accidents must be reported 

to the National Transportation Safety Board (NTSB) per instructions contained on the 

NTSB Web site: www.ntsb.gov. 

If this exemption permits closed-set motion picture and television filming and production, 

the following additional conditions and limitations apply.
31

29. The operator must have a motion picture and television operations manual (MPTOM) 

as documented in this grant of exemption.

30. At least 3 days before aerial filming, the operator of the UAS affected by this 

exemption must submit a written Plan of Activities to the local Flight Standards District 

Office (FSDO) with jurisdiction over the area of proposed filming. The 3-day notification 

may be waived with the concurrence of the FSDO. The plan of activities must include at 

least the following:

a. Dates and times for all flights;

b. Name and phone number of the operator for the UAS aerial filming conducted 

under this grant of exemption;

c. Name and phone number of the person responsible for the on-scene operation of 

the UAS;

d. Make, model, and serial or N-Number of UAS to be used;

e. Name and certificate number of UAS PICs involved in the aerial filming;

f. A statement that the operator has obtained permission from property owners and/or 

local officials to conduct the filming production event; the list of those who gave 

permission must be made available to the inspector upon request;

g. Signature of exemption holder or representative; and

h. A description of the flight activity, including maps or diagrams of any area, city, 

town, county, and/or state over which filming will be conducted and the altitudes 

essential to accomplish the operation.

31. Flight operation may be conducted closer than 500 feet from participating persons 

consenting to be involved and necessary for the filming production, as specified in the 

exemption holder’s MPTOM.

2. Reasons Why An Exemption From The Requirements Of Sections 61.23(a) & 

(c) Would Not Adversely Affect Safety.

RS&H submits that an equivalent level of safety established by Sections 61.23(a) & (c) 

will be maintained because no PIC will be allowed to operate the Inspire 1 UAS unless that PIC 

holds either a valid FAA-issued medical certificate or a valid U.S. issued driver’s license. 

Additionally, no PIC will be allowed to operate the 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 Inspire 1 UAS in a manner consistent with the exemption, including evasive 

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

and structures.
32

Considering RS&H’s proposed area of operations, the relatively small size of the Inspire 

1 UAS, and the operating limitations set forth in this Petition, as well as the parallel nature of 

sport pilot, recreational pilot, and private pilot medical requirements, relating to the proposed 

operations, RS&H submits the additional requirements of at least a third-class airman medical 

certificate would not correlate to RS&H’s proposed operations.

The Inspire 1 has been the subject of a previous Grant of Exemption from Sections 

61.23(a) & (c) (Exemption No. 11224). Additionally, the FAA has previously granted relief 

from Sections 61.23(a) & (c) specific to UAS, in circumstances similar, in all material respects, 

to those presented herein (e.g. Exemption Nos. 11213, 11221, 11222, 11223, 11224, 11225,

11226, 11227, 11228, 11229, 11230, 11237, 11238, 11239, 11240, 11241).

3. Reasons Why An Exemption From The Requirements Of Sections 

61.101(e)(4) & (e)(5), 61.113(a), and 61.315(a) Would Not Adversely Affect 

Safety.

RS&H submits that an equivalent level of safety established by Sections 61.101(e)(4) & 

(e)(5), 61.113(a), and 61.315(a) will be maintained because no PIC will be allowed to operate the 

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 Inspire 1 UAS in a manner consistent with 

the exemption, including evasive and emergency maneuvers and maintaining appropriate 

distances from people, vessels, vehicles, and structures.

Considering RS&H’s proposed area of operations, and the operating limitations set forth

above; the parallel nature of sport pilot, recreational pilot, and private pilot aeronautical 

knowledge requirements, with respect to the proposed operations, to those of commercial pilot 

requirements (See Exemption Nos. 11062 and 11213); and the airmanship skills necessary to 

safely operate the Inspire 1 UAS, RS&H submits that the additional manned airmanship 
33

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

necessary for RS&H’s specific proposed flight operations.

The Inspire 1 has been the subject of previous Grants of Exemption from Sections 

61.101(e)(4) & (e)(5) (Exemption No. 11224), Section 61.61.113(a) (Exemption Nos. 11204 and 

11224), and Section 61.315(a) (Exemption No. 11224). The FAA has previously granted relief 

from Sections 61.101(e)(4) & (e)(5) and 61.315(a) specific to UAS, in circumstances similar, in 

all material respects, to those presented herein (e.g. Exemption Nos. 11213, 11221, 11222, 

11223, 11224, 11225, 11226, 11227, 11228, 11229, 11230, 11237, 11238, 11239, 11240, 

11241). Additionally, the FAA has previously granted relief from Section 61.113(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, 11136, 11138, 11150, 

11153, 11156, 11158, 11159, 11160, 11161, 11170, 11171, 11172, 11174, 11176, 11177, 11178,

11184, 11185, 11188, 11189, 11191, 11192, 11193, 11194, 11195, 11204, 11206, 11208, 11209, 

11213, 11215, 11216, 11217, 11218, 11220, 11221, 11222, 11223, 11224, 11225, 11226, 11227, 

11228, 11229, 11230, 11237, 11238, 11239, 11240, 11241).

RS&H will not allow any PIC to operate the Inspire 1 UAS unless that PIC has 

demonstrated, by meeting minimum flight-hour requirements or the Inspire 1 UAS training and 

currency requirements, that the PIC is able to safely operate the 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 pilot (with a minimum of 5 hours of those

hours as a UAS pilot operating the same make and model of UAS to be used for operations under 
34

the exemption). In addition to the hour requirements, the PIC must accomplish 3 take-offs 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 RS&H’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 take-offs 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 RS&H’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 experiencebuilding 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, RS&H will ensure safe operations by not allowing any PIC to operate the 

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 Inspire 1 UAS in a manner consistent with 

the exemption, including evasive and emergency maneuvers and maintaining appropriate 

distances from people, vessels, vehicles and structures. 
35

4. Reasons Why An Exemption From The Requirements Of Section 91.7(a)

Would Not Adversely Affect Safety.

The equivalent level of safety established by Section 91.7(a) will be maintained because 

prior to every flight, RS&H will ensure that the Inspire 1 UAS is in an airworthy condition based 

upon the Inspire 1 UAS’s compliance with its relevant operating documents (i.e., Inspire 1 User 

Manual, Inspire 1 Quick Start Guide, Inspire 1 1345 Propeller Locks Quick Start Guide, Inspire 

1 Intelligent Flight Battery Safety Guidelines, Inspire 1 Safety Guidelines, and Inspire 1 

Maintenance Manual), and as stated in the conditions and limitations herein.

The Inspire 1 has been the subject of a previous Grants of Exemption from Section 

91.7(a) (Exemption Nos. 11204 and 11224). 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. 11109, 11110, 11136, 11138, 11150, 11153, 11156, 

11157, 11158, 11159, 11160, 11161, 11166, 11167, 11170, 11171, 11172, 11174, 11177, 11178,

11184, 11185, 11188, 11189, 11191, 11192, 11193, 11194, 11195, 11204, 11206, 11208, 11209, 

11213, 11215, 11216, 11217, 11218, 11220, 11221, 11222, 11223, 11224, 11225, 11226, 11227, 

11228, 11229, 11230, 11237, 11238, 11239, 11240, 11241).

5. Reasons Why An Exemption From The Requirements Of Section 91.119(c) 

Would Not Adversely Affect Safety.

The equivalent level of safety established by Section 91.119(c) will be maintained 

because in any operation to be conducted closer than 500 feet from any nonparticipating persons, 

barriers or structures will be present to sufficiently protect any nonparticipating persons from 

debris in the event of an accident during operation of the Inspire 1 UA, which weighs less than 

eight (8) pounds and will be operated below an altitude of 400 feet AGL. The nonparticipating 

persons will be required to remain in the area of protection, and if any nonparticipating person
36

leaves the area of protection and is within 500 feet of the Inspire 1 UA, flight operations will

cease immediately.

Additionally, any operation to be conducted closer than 500 feet from persons, vessels, 

vehicles, and structures would first require the permission of the land owner/controller and a 

safety assessment of the risk of operating closer to those objects by the PIC.

The Inspire 1 has been the subject of a previous Grants of Exemption from Section 

91.119(c) (Exemption Nos. 11204 and 11224). Additionally, the FAA has previously granted 

relief from Section 91.119(c) 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, 11111, 11112, 11114, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 

11159, 11160, 11161, 11166, 11167, 11170, 11171, 11172, 11174, 11176, 11177, 11178, 11184, 

11185, 11188, 11189, 11191, 11192, 11193, 11194, 11195, 11204, 11206, 11208, 11209, 11213, 

11215, 11216, 11217, 11218, 11220, 11221, 11222, 11223, 11224, 11225, 11226, 11227, 11228, 

11229, 11230, 11237, 11238, 11239, 11240, 11241).

6. 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 of the Inspire 1 UA will be reported to air traffic control (ATC) in feet above ground 

level (AGL), and RS&H will operate the Inspire 1 UA within visual line of sight, at or below 400

feet AGL. Furthermore, the altitude information of the Inspire 1 UA will be provided to the PIC

via a barometric pressure sensor, GPS equipment, a Visual Positioning System using ultrasonic 

and image data, and a radio communications telemetry data link, which downlinks from the UA 

to the Remote Controller for active monitoring of the flight path and altitude. Prior to each 

flight, a zero altitude initiation point is automatically established by the UAS at ground level. 
37

The Inspire 1 has been the subject of a previous Grant of Exemption from Section 91.121

(Exemption No. 11204). Additionally, the FAA has previously granted relief from Section 

91.121 specific to UAS, in circumstances similar, in all material respects, to those presented 

herein (e.g. Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11136,

11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161, 11166, 11167, 11170, 11171, 

11174, 11176, 11177, 11178, 11184, 11185, 11188, 11189, 11191, 11192, 11193, 11194, 11195, 

11204, 11206, 11208, 11209, 11213, 11215, 11216, 11217, 11218, 11220, 11221, 11222, 11223, 

11224, 11225, 11226, 11227, 11228, 11229, 11230, 11237, 11238, 11239, 11240, 11241).

7. Reasons Why An Exemption From The Requirements Of Section 

91.151(a)(1) 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(a)(1) as a result of (1) the technical specifications of the Inspire 1 UAS; 

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

operations. Accordingly, RS&H will ensure that it will safely operate the battery powered Inspire 

1 UA during daylight hours in visual metrological conditions (VMC) under visual flight rules 

(VFR), with enough battery power for the Inspire 1 UA to fly for a total duration of 13 minutes 

to the first point of intended landing and, assuming normal cruising speed, to fly after that for at 

least five (5) minutes (i.e., approximately 30 percent battery power remaining)

In addition to the level of safety established by the technical specifications of the UAS; 

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

Inspire 1 UAS provides audible and visual warnings to the PIC at the Remote Controller when 

the UA has low battery power remaining. Together these factors will ensure an equivalent level 

of safety established by 14 C.F.R. Section 91.151(a)(1).
38

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 also been granted for manned aircraft to operate at less than the 

minimums prescribed in Section 91.151, including Exemption Nos. 2689, 5745, and 10650. 

The Inspire 1 has been the subject of a previous Grants of Exemption from Section 

91.151(a)(1) (Exemption Nos. 11204 and 11224). Additionally, the FAA has previously granted 

relief from Section 91.151(a)(1) 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, 11112, 11136, 11138, 11150, 11153, 

11156, 11157, 11158, 11159, 11160, 11161, 11166, 11167, 11170, 11171, 11172, 11174, 11176, 

11177, 11178, 11184, 11185, 11188, 11189, 11191, 11192, 11193, 11194, 11195, 11204, 11206, 

11208, 11209, 11213, 11215, 11216, 11217, 11218, 11220, 11221, 11222, 11223, 11224, 11225, 

11226, 11227, 11228, 11229, 11230, 11237, 11238, 11239, 11240, 11241).

8. 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, RS&H 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 all maintenance, 

alterations, and preventive maintenance of the Inspire 1 UAS performed by RS&H will be in 

accordance with the methods, techniques, and practices prescribed in the operating documents

(i.e., Inspire 1 User Manual, Inspire 1 Quick Start Guide, Inspire 1 1345 Propeller Locks Quick 

Start Guide, Inspire 1 Intelligent Flight Battery Safety Guidelines, Inspire 1 Safety Guidelines, 

and Inspire 1 Maintenance Manual). Furthermore, only the Original Equipment Manufacturer 
39

(OEM) or qualified OEM maintainers will perform higher level inspections and maintenance per 

the operating documents and OEM standards. RS&H will document and maintain all 

maintenance records for the Inspire 1 UAS. 

Since the Inspire 1 UAS will be inspected as prescribed by the operating documents, 

RS&H will maintain the equivalent level of safety established by Sections 91.405(a),

91.409(a)(1), and 91.409(a)(2). The following operating documents are attached hereto, 

identified as the following Exhibits: (A) The Inspire 1 User Manual; (B) The Inspire 1 Quick 

Start Guide; (C) The Inspire 1 1345 Propeller Locks Quick Start Guide; (D) The Inspire 1 

Intelligent Flight Battery Safety Guidelines; (E) The Inspire 1 Safety Guidelines; and (F) The 

Inspire 1 Maintenance Manual. The foregoing exhibits contain proprietary information and are

to be held in a separate file pursuant to 14 C.F.R. § 11.35(b).

Likewise, the exemption sought will not adversely affect safety because all maintenance, 

alterations, or preventive maintenance of the Inspire 1 UAS will be performed by RS&H in 

accordance with the methods, techniques, and practices prescribed in the operating documents. 

Only the Original Equipment Manufacturer (OEM) or qualified OEM maintainers will perform 

higher level inspections and maintenance per the operating documents and OEM standards. 

RS&H will document and maintain all maintenance records for the Inspire 1 UAS. 

Furthermore, an equivalent level of safety established by Sections 91.407 (a)(1), 

91.417(a), and 91.417(b) will be maintained because RS&H will document and maintain all of 

the maintenance records for the Inspire 1 UAS. 

The Inspire 1 has been the subject of a previous Grants of Exemption from Sections

91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), And 91.417(a) & (b) (Exemption Nos. 11204 and 

11224). Additionally, previous exemptions granted by the FAA concerning these Sections
40

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

limitations of the UAS are considered (e.g. Exemption Nos. 11062, 11063, 11064, 11065, 11066, 

11067, 11080, 11109, 11110, 11112, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 

11160, 11161, 11166, 11167, 11170, 11171, 11172, 11174, 11176, 11177, 11178, 11184, 11185, 

11188, 11189, 11191, 11192, 11193, 11194, 11195, 11204, 11206, 11208, 11209, 11213, 11215, 

11216, 11217, 11218, 11220, 11221, 11222, 11223, 11224, 11225, 11226, 11227, 11228, 11229, 

11230, 11237, 11238, 11239, 11240, 11241).

 9. 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, RS&H requests that the FAA

prescribe special conditions for the intended operation of the Inspire 1 UAS, which contain such 

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

that established by 14 C.F.R. Part 21, Subpart H, and 14 C.F.R. §§ 61.23(a) & (c), 61.101(e)(4) 

& (e)(5), 61.113(a), 61.315(a), 91.7(a), 91.119(c), 91.121, 91.151(a), 91.405(a), 91.407(a)(1), 

91.409(a)(1) & (a)(2), AND 91.417(a) & (b). Such special conditions will permit safe operation 

of the UA for the limited purpose of conducting aerial acquisitions within the NAS 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. 
41

§ 21.16, for operation of the 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 RS&H’s intended operation of the Inspire 1 UAS, which contain 

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

equivalent to that established by 14 C.F.R. Part 21, Subpart H, and 14 C.F.R Sections 61.23(a) & 

(c), 61.101(e)(4) & (e)(5), 61.113(a), 61.315(a), 91.7(a), 91.119(c), 91.121, 91.151(a), 91.405(a), 

91.407(a)(1), 91.409(a)(1) & (a)(2), AND 91.417(a) & (b).

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

The Rules From Which RS&H, Inc. Seeks Exemption:

RS&H, Inc. seeks exemption from the requirements of 14 C.F.R. Sections 61.23(a) & (c), 

61.101(e)(4) & (e)(5), 61.113(a), 61.315(a), 91.7(a), 91.119(c), 91.121, 91.151(a), 

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 RS&H, Inc. Seeks:

This exemption will permit RS&H, Inc. to commercially operate an Unmanned Aircraft 

System (UAS) for the purpose of conducting aerial acquisitions within the National 

Airspace System (NAS).

G. Any Additional Information, Views, Or Arguments Available To Support RS&H, 

Inc.’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
42

may operate safely in the NAS. As such, RS&H’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, RS&H will operate the 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, RS&H, Inc. 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 Inspire 1 UAS commercially, without an airworthiness certificate, for the limited

purpose of conducting aerial acquisitions within the National Airspace System (NAS). 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 RS&H, Inc. to safely, efficiently, and economically operate the Inspire 1 UAS

commercially within the NAS.

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

Modernization and Reform Act of 2012, Section 333, RS&H, Inc. respectfully requests that the 

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

61.23(a) & (c), 61.101(e)(4) & (e)(5), 61.113(a), 61.315(a), 91.7(a), 91.119(c), 91.121, 

91.151(a), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b), and permit 
43

RS&H, Inc. to operate the DJI Inspire 1 UAS commercially for the purpose of conducting aerial 

acquisitions within the NAS.

Dated: April 03, 2015 Respectfully submitted,

The Aviation Law Firm

/s/ Gregory S. Winton

____________________________

Gregory S. Winton, Esq.

1997 Annapolis Exchange Parkway

Suite 300

Annapolis, Maryland 21401

Tel: (301) 294-8550

Fax: (866) 568-9886

Attorney for Petitioner 

cc: James H. Williams, AFS-80

Robert Pappas

Dean Griffith, Esq.