August 18, 2015

Exemption No. 12491

Regulatory Docket No. FAA–2015–1634

Mr. Kyle Ferreira

Bergen County Aerial Media

286 Werimus Road

Woodcliff Lake, NJ 07677

Dear Mr. Ferreira:

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 letters dated April 26 and August 1, 2015, you petitioned the Federal Aviation 

Administration (FAA) on behalf of Bergen County Aerial Media (hereinafter petitioner or

operator) for an exemption. The petitioner requested to operate an unmanned aircraft system 

(UAS) to conduct aerial photography.

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.

The petitioner requested relief from 14 CFR part 21, Certification procedures for products 

and parts, Subpart H—Airworthiness Certificates. 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 
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aircraft and its operation, the Secretary of Transportation has determined that this aircraft 

meets the conditions of Section 333. Therefore, the FAA finds that the requested 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, Bergen County Aerial Media 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, Bergen County Aerial Media 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 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, 
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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 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.
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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, 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.
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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 

(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.
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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.

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 August 31, 2017, unless sooner superseded or rescinded.

Sincerely,

/s/

John S. Duncan

Director, Flight Standards Service

Enclosures
April 26, 2015

From: Kyle Ferreira, Bergen County Aerial Media

286 Werimus Road

Woodcliff Lake, NJ 07677.3

Kyle.Ferreira@yahoo.com

Re: Exemption Request under Section 333 of the FAA Reform Act

To Whom It May Concern,

I would like to begin my petition by introducing myself to you so that you understand my 

background and concerns with safety and operation of a UAS. I have been involved with remote 

controlled aircrafts for over 10 years, and in that time have operated various types from fixed wing to 

single and multi-rotor platforms. As a hobbyist, I have flown in a variety of locations, and with the 

integration of first-person-view (FPV) cameras, I have come to love the breathtaking views that it 

provides. The moment that I printed out my first aerial panoramic picture of my house, I knew that this 

would be a service that millions would want, and I would love to provide that service. The ability to view 

areas and properties from the perspective of a bird is simply awe-inspiring. 

I have been involved in public service for over 12 years and am currently a full- time police 

officer, as well as a volunteer fire-fighter/ EMT. The sole existence of my career has been to help people 

and to ensure their safety. I have taken this concept into my personal life, especially when I operate any 

UAS. Prior to the NPRMs regarding commercial UAS operations, I had already completed FAA- approved 

ground schooling for my Private Pilot’s License, and passed the Airmen Knowledge Test. Although I 

understand the classes do not improve your remote controlled operational skills regarding the flight of 

the UAS, I wanted to become extremely knowledgeable regarding National Air Space and FAA 

regulations so that I was able to operate in safe manner, away from any manned aircraft or other safety 

concerns.

Currently, I own the DJI Inspire 1 quadcopter. With this platform, I have logged over 500 hours 

of flight as a hobbyist. I feel that this is a great machine, and allows me to feel comfortable operating it 

due to its multiple safety features including a failsafe return to home, vision positioning system, and 

preprogrammed “no-fly zones”. The technology that the Inspire possesses would be a great tool to the 

public as I can provide them with a multitude of services including videography and still photography

that the average resident may not be able to afford. 

My petition is modeled after the Douglas Trudeau exemption (Docket #:2014-FAA-0481

Exemption #:11138) which has proposed many of the same uses and safety measures that I address. My 

petition is also the same model UAS and has the same potential uses as exemption numbers: 11418, 
August 1, 2015

From: Kyle Ferreira, Bergen County Aerial Media

286 Werimus Road

Woodcliff Lake, NJ 07677

Kyle.Ferreira@yahoo.com

(201) 913-8500

Re: Exemption Request under Section 333 of the FAA Reform Act

To Whom It May Concern,

Today, 8/1/15, I received a letter advising that you are unable to process my request for an 

exemption from Title 14, Code of Federal Regulations (14 CFR), stating that I must provide the reasons 

why granting the request would be in the public interest; that is how it would benefit the public as a 

whole. The following response is how I feel granting me this exemption would directly benefit the 

public’s interest and the community around me:

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

service. It is able to capture images that allow for a higher level of marketing and advertising. This in 

turn makes the property appealing to more buyers, resulting in a quicker sale of their home. Quicker 

home sales also help accelerate the economy as a whole. Property Buyers experience the benefit of 

encompassing a whole property, sometimes several acres, in one photo or a short video. Not only does 

this benefit the specific home seller or home buyer, but it benefits the general public because it is much 

more efficient than traditional ways of using a plane or helicopter to achieve the same result. We can 

now provide this level of service while being conservative with fuel, time, emissions, noise, and other 

resources. Considering size, weight, speed, and absence of combustible fuels, my UAS will have much 

less of a safety concern for the general public when compared to larger manned aircraft.

If you have any further questions, or would like to speak to me personally please contact me at the 

above listed information

Respectfully Submitted,

Kyle Ferreira, Owner

Bergen County Aerial Media
11314, 11359, 11342, 11323, 11336, 11398, 11416, 11384, and 11385. At this time, I would like to begin 

my formal petition for exemption to operate a UAS.

To the Federal Aviation Administration,

I, Kyle Ferreira, the owner of Bergen County Aerial Media, hereby request exemption from the 

following subsections of Title 14 of the Code of Federal Regulations (14 CFR):

14 CFR Part 21 subpart H

14 CFR 45.23 (b)

14 CFR 61.113 (a)

14 CFR 61.113 (b)

14 CFR 91.7 (a)

14 CFR 91.9 (b) 2

14 CFR 91.103

14 CFR 91.109

14 CFR 91.121

14 CFR 91.151 (a)

14 CFR 91.203 (a)

14 CFR 91.203 (b)

14 CFR 91.405 (a)

14 CFR 91.407 (a) 1

14 CFR 91.409 (a) 2

14 CFR 91.417 (a)

14 CFR 91.417 (a)

I support my request with the following information:

My intention is to operate the DJI Inspire 1 quadcopter. The Inspire 1 is comprised of a 

multirotor unmanned aircraft and a portable ground station. The Inspire 1 is a quadcopter that does not 

exceed 55lbs (including payload). It is equipped with four model “DJI 3510” motors, powered by a six cell 
lithium-ion battery that has a maximum airspeed of 22 m/s. The Inspire 1 has a high definition camera 

that is capable of producing high definition videos and still pictures. My intentions are to use this camera 

to photograph aerial views that cannot normally be achieved without an aircraft. I plan to then provide

these pictures to various clients including: real estate agents, private home owners, and commercial 

businesses. As stated before, my primary concern is the safety of any individual, structure, or craft on 

the ground, or anywhere in National Air Space. I plan on adhering to all of the operational 

recommendations of the manufacturer, as well as enhancing them by the following set of Operational 

Guidelines:

1.) The UAS will weigh less than 55 lbs. (including payload)

2.) Flights will be operated within visual line of sight of the Pilot in Command (PIC) and/ or the 

visual observer (VO).

3.) The PIC and VO will be in constant communication by voice, or by radio.

4.) The PIC will hold either an airline transport, commercial, private, recreation, or sport Pilots

license, with either a FAA second class Airman medical certificate or higher; or a valid U.S. 

driver’s license issued by the State or Federal Government.

5.) The PIC must have a minimum of 20 hours of flight time operating the UAS.

6.) Maximum flight time will not exceed 20 minutes in duration. Flights will be terminated when the 

battery reaches a 30% level, or 20 minutes in duration, whichever comes first.

7.) Flights will be operated at an altitude of no more than 400 feet above ground level (AGL). 

8.) The PIC will utilize the UAS’s global positioning system (GPS) flight safety feature so if 

communications are lost between the radio and UAS, the craft will slowly hover, return to a 

predetermined location, and safely land autonomously.

9.) The PIC will contact the respective airport if operations will be within a 5 miles radius, and will 

provide them contact information as well as flight times, durations, elevations, and other 

pertinent information.

10.)The PIC will operate the UAS in reasonably safe environments that are strictly controlled and 

where prior authorization has been granted.

11.)The PIC will operate in areas where a thorough preflight size up has been conducted to identify 

power lines, elevated lights, airports, actively populated areas, or any other potential hazard.

12.)The PIC will operate only after conducting an extensive preflight checklist, where the UAS and 

ground station have been inspected following the strict set of protocols, during which safety is a 

primary concern.

13.) The PIC will have an emergency procedure in place to abort flights in the event of an unsafe 

condition or potential danger.

In regards to 14 CFR Part 21 subpart H (Airworthiness Certificates) this subsection establishes 

the procedural requirements for the issuance of airworthiness certificates as required by FAR §91.203 

(a) (1). Given the DJI Inspire 1’s size, weight, maximum air speed, and limited operating area where the 

aircraft will be utilized, an exemption meets the requirements for level of safety under 14 CFR part 11 

and Section 333 of P.L. 112-95 (Section 333).

I request an exemption 14 CFR 45.23- Marking of aircraft, due to the fact that the UAS does not 

have an entrance to the cabin, cockpit or pilot station on which the word “experimental” can be placed. 
Also, due to the size of the UAS, two inch lettering would be impossible. Regardless, I will place the word 

“experimental” on its fuselage as required by § 45.29 (f) so that the PIC or anyone assisting him as a VO 

or spotter will see the markings.

14 CFR 91.405 (a), 14 CFR 91.407 (a)1, 14 CFR 91.409(a) 2, 14 CFR 91.417 (a), and 14 CFR 91.417 

(b) state that maintenance inspections may be required for civil aircraft. This exemption should be 

granted since they only apply to an aircraft with an airworthiness certificate. In order to ensure that the 

UAS is constantly airworthy and safe, I will perform a thorough preflight checklist/ inspection of the UAS 

as outlined in my operational documents. I will also follow all recommendations of the manufacturer’s 

maintenance manual.

14 CFR 61.113 (a) and 14 CFR 61.113 (b) states that no persons who holds a private pilot’s 

certificate may act as Pilot in Command of an aircraft carrying passengers or property for compensation 

or hire. I am seeking an exemption to this since my UAS does not carry any pilots or passengers. 

Although helpful, a pilot’s license will not ensure remote control piloting skills. The risks associated with 

the operation of my UAS is extremely less than the risk levels associated with commercial activities 

outlined in 14 CFR 61.

14 CFR 91.7(a) is a regulation that requires that no person operate a civil craft unless it is in 

airworthy condition. Due to there not being an airworthiness certificate issued to my UAS, this would 

not be possible. The size of the aircraft, as well as the strict safety checklist and inspection that must be 

performed before each flight will ensure that the UAS is the equivalent level of safety.

14 CFR 91.9 (b) 2 requires that No person may operate a U.S.-registered civil aircraft ... (2) For 

which an Airplane or Rotorcraft Flight Manual is not required by §21.5 of this chapter, unless there is 

available in the aircraft a current approved airplane or Rotorcraft Flight Manual, approved manual 

material, markings, and placards, or any combination thereof. Given the small size of my UAS, it has not 

place to store such a flight manual on the aircraft. The equivalent safety/ flight manual will be stored 

with the PIC on the ground in case of an emergency.

14 CFR 91.103 requires that each PIC takes certain actions prior to each flight, to ensure the 

safety of the flight. I am requesting an exemption and will require that the PIC take all the necessary 

preflight actions, including but not limited to: reviewing the weather patterns, reviewing battery 

requirements, ensuring a safe take off/ landing zone, and completing a thorough preflight checklist prior 

to each flight.

14 CFR 91.109 provides that no person may operate a civil aircraft (except a manned free 

balloon) that is being used for flight instruction unless that aircraft has fully functioning dual controls. 

The UAS by design only has one set of controls to operate. The equivalent level of safety is provided by 

the fact that of UAS’s size and speed, as well as not be carrying any pilots or passengers. 

14 CFR 91.121 requires each person operating an aircraft to maintain cruising altitude by 

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

altimeter setting available before departure.” The DJI Inspire 1 does not have an altimeter, but instead a 

GPS altitude reading that is calibrated to the point of takeoff. An equivalent level of safety will be 

achieved by the PIC by confirming the altitude at the point of takeoff.
14 CFR 91.151 (a) prohibits an individual from beginning “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; or (2) At night, to fly after that for at least 45 minutes.” The battery of the DJI 

Inspire 1 provides approximately 25 minutes of powered flight thus making it impossible to meet the 30 

minute reserve requirement in 14 CFR 91.151. Given the limitations of the UAS proposed flight area and 

the location of its proposed operations within a predetermined area, a longer time frame for flight in 

daylight or twilight VFR conditions is reasonable. Maximum flight time will not exceed 20 minutes in 

duration. Flights will be terminated when the battery reaches a 30% level, or 20 minutes in duration, 

whichever comes first.

In a world that is pushed forward by technology, UAS’s are becoming more prevalent in today’s 

society whether they are used for hobbyist or commercial purposes. Everyone from realtors to 

commercial businesses are interested in the views from the air, but to small businesses, the expense of 

hiring a private airplane or helicopter is cost prohibitive. Granting an exception to me will allow this 

service to be provided to these interested parties at a much lower cost, and will have a greater impact 

on the society around me. I feel that not only will my photos and video have a positive effect on the 

clients I do business with, but also the community at large when they learn of the safety procedures that 

I have implemented.

Your consideration in this matter is greatly appreciated.

Respectfully Submitted,

Kyle Ferreira

Bergen County Aerial Media