UNITED STATES OF AMERICA

DEPARTMENT OF TRANSPORTATION

FEDERAL AVIATION ADMINISTRATOR

WASHINGTON, DC

Regulatory Docket No.____________________

PETITION FOR EXEMPTION OF:

HONOLULU BOARD OF WATER SUPPLY

FOR AN EXEMPTION SEEKING RELIEF FROM THE REQUIREMENTS OF TITLE 14 OF THE CODE OF 

FEDERAL REGULATIONS SECTIONS 45.23, 61.113(a) & (b), 91.7(a), 91.121, 91.171(b), 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 June 09, 2015,

Aaron Woods, GIS Analyst

Honolulu Board of Water Supply

630 South Beretania St.

Honolulu, HI. 96843

808-748-5256

awoods@hbws.org
2

TABLE OF CONTENTS

 Page

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

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

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

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

BASIS FOR PETITION..................................................................................................................................................4

NAME AND ADDRESS OF PETITIONER.......................................................................................................6

THE SPECIFIC SECTIONS OF 14 C.F.R FROM WHICH HBWS SEEKS EXEMPTION..................................6

THE EXTENT OF RELEIVE HBWS SEEKS AND THE REASON HBWS SEEKS THE RELIEF..........................9

THE REASONS WHY GRANTING HBWS’ REQUEST FOR EXEMPTION WOULD BE IN THE PUBLIC 

INTEREST.....................................................................................................................................................10

THE REASON WHY GRANTING THE EXEMPTION WOULD NOT ADVERSLY AFFECT SAFETY............12

SUMMARY THAT CAN BE PUBLISHED IN THE FEDERAL REGISTER......................................................22

ANY ADDITIONAL INFORMATION, VIEWS, OR ARGUEMTNS AVAILABLE TO SUPORT HBWS 

REQUEST.....................................................................................................................................................22

CONCLUSION............................................................................................................................................................23

Appendix A, Inspire 1 Maintenance Manual........................................................................................................24

Appendix B, Inspire 1 Safety Guidelines...............................................................................................................27
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

GCS Ground Control Station

GPS Global Positioning System

LOL Loss of Link

NAS National Air Space

NOTAM Notice to Airman

PIC Pilot In Command

RTH Return To Home

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

SOP Standard Operating Procedures

UAS Unmanned Aircraft System

VFR Visual Flight Rules

VLOS Visual Line of Site

VMC Visual Meteorological Conditions

VO Visual Observer

VTOL Vertical Takeoff and Landing
4

SUMMARY

Honolulu Board of Water Supply seeks exemption from the requirements of 14 C.F.R §§ 45.23, 

61.113(a) & (b), 91.7(a), 91.121, 91.171(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) 

& (b), to commercially operate an Unmanned Aircraft System pursuant to Section 333 of the FAA 

Modernization and Reform Act of 2012 (FMRA). This exemption will permit Honolulu Board of Water 

Supply to operate an Unmanned Aircraft System (UAS) for commercial purpose of conducting aerial 

acquisitions, research and inspections over certain rural areas of the United States.

INTRODUCTION AND INTERESTS OF THE PETITIONER

Honolulu Board of Water Supply (hereinafter referred to as “HBWS”) was founded in 1929 and

manages the municipal water resources and distribution systems on the island of Oahu Hawaii. HBWS is 

a semi-autonomous agency that is responsible for providing affordable, clean, and safe drinking water to 

the over 1.5 million residents and visiting tourists daily across Oahu. HBWS firmly believes in combining 

innovation, quality and safety into all of its operations, in order to best aid its customers and the 

communities it serves.

As set forth in this Petition, HBWS seeks to commercially operate its DJI Inspire 1 UA over 

certain rural areas of the State of Hawaii for the purpose of conducting aerial acquisitions and research, 

videography, gathering of land cover data, natural resources, conservation, construction, infrastructure 

management and inspections, monitoring assessments, search and rescue operations, and 

reconnaissance in support of disaster or emergency situations.

BACKGROUND

Unmanned Aircraft Systems: DJI Inspire 1 UAS

HBWS seeks an exemption to operate the DJI Inspire 1 UAS for commercial purposes within the NAS. 

The DJI Inspire 1 UAS is comprised of a vertical takeoff and landing (VTOL) Unmanned Aircraft (UA) and a 

transportable Ground Control Station (GCS). The DJI Inspire 1 UA has a maximum gross weight of 

approximately 6.7 pounds, while having a diameter of 26 inches, and a maximum speed of 49 mph 

(approximately 42 knots). The DJI Inspire 1 UA is equipped with four propellers, each being driven by a 

Lithium Polymer battery powered electric motor.

BASIS FOR PETITION

Petitioner, HBWS, 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, 

entitled Special Rules for Certain Unmanned Aircraft Systems, hereby petitions the Administrator to 

operate the DJI Inspire 1 UAS in the National Airspace System (NAS), and for an exemption from the 

requirements of 14 C.F.R. §§45.23, 61.113(a) & (b), 91.7(a), 91.121, 91.171(b), 91.405(a), 91.407(a)(1), 

91.409(a)(1) & (a)(2), and 91.417(a)&(b).
5

In consideration of the size, weight and speed, as well as the limited area of intended operation 

associated with the unmanned aircraft, HBWS’s use of the DJI Inspire 1 meets the conditions of FMRA 

Section 333 and therefore, will not require an airworthiness certificate in accordance with 14 C.F.R. Part 

21, Subpart H.

Accordingly, HBWS requests relief from Sections 45.23(b), 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.

HBWS submits that the requested relief is proper since the equivalent level of safety will be 

ensured. HBWS will use FAA qualified technicians to perform maintenance, alterations, or preventive 

maintenance on the UAS using methods, techniques, and practices prescribed in the manufacturer’s 

user/safety guidelines manual. Furthermore, HBWS will document and maintain all maintenance 

records for the DJI Inspire 1 UAS.

Relief from certain requirements of section 61.113(a) & (b), entitled Private pilot privileges and 

limitations; Pilot in command, is requested by HBWS to the extent necessary to allow a Pilot in 

Command (PIC) holding a sport pilot or higher level pilot certificate, and an airman medical certificate or

valid Hawaii State Driver’s License, and who has completed the DJI Inspire 1 UAS training and currency 

requirements, to conduct the proposed UAS flight operations. HBWS submits that the conditions and 

limitations set forth herein will ensure the safety of the NAS, as well as the safety of persons and 

property on the ground.

HBWS seeks relief from Section 91.7(1), entitled Civil aircraft airworthiness, because the DJI 

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

H. As such, HBWS submits that it will ensure that the DJI Inspire 1 UAS is in an airworthy condition prior 

to every flight, be determining that the UAS is in compliance with its type design pursuant to the DJI 

Inspire 1 User Manual (see Appendix A) and Inspire 1 Maintenance Manual (see Appendix B) and that 

the aircraft is in a condition for safe flight.

HBWS also seeks an exemption from the requirements of Section 91.121, entitled Altimeter 

Settings, as the DJI Inspire 1 UAS will not have a typical barometric altimeter onboard. However, 

altitude information of the DJI Inspire 1 UA will be provided to the PIC via Global Positioning System 

(GPS) equipment and a radio communications telemetry data link, which downlinks from the UA to the 

GCS for active monitoring of the flight path. This altitude information, combined with the HBWS’s 

operation of the DJI Inspire 1 UA within visual line of sight, at or below 400 feet AGL, will ensure a level 

of safety equivalent to Section 91.121.

Additionally, HBWS seeks an exemption from the requirements of Section 91.171(b), entitled 

Fuel requirements for flight in VFR conditions. HBWS submits that safety will not be affected by 

operations of the DJI Inspire 1 UA during daylight hours under Visual Flight Rules (FVR) and Visual 

Meteorological Conditions (VMC), with enough battery power to fly for a total of 17 minutes to the first 

point of intended landing and, assuming normal cruising speed, to fly after that for at least five minutes.
6

In accordance with 14 C.F.R 11.81, HBWS provides the following information in support of its 

petition for exemption:

A. Name and Address of the Petitioner: 

Honolulu Board of Water Supply

630 South Beretania St.

Honolulu, HI. 96843

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

Aaron Woods (GIS Analyst V)

Honolulu Board of Water Supply 

630 South Beretania St.

Honolulu, HI. 96843

808-748-5256

awoods@hbws.org

B. The Specific Sections of 14 C.F.R. from which HBWS Seeks Exemption.

1. HBWS seeks exemption from the Requirements of Section 61.113(a) & (b).

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

Subsections (a) & (b) prescribe the following, in relevant part:

(a) No person who holds a private pilot certificate may act as pilot in command (PIC) of 

an aircraft that is carrying passengers or property for compensation or hire; nor may 

that person, for compensations or hire, act as PIC of an aircraft.

(b) A private pilot may, for compensation or hire, act as PIC of an aircraft in connection 

with any business or employment if-

(1) The flight is only incidental to that business or employment; and

(2) The Aircraft does not carry passengers or property for compensation or hire.

2. HBWS seeks exemption from the Requirements of Section 91.7 (a).

Section 91.7 entitled Civil aircraft airworthiness, subsection (a), states the following:

(a) No person may operate a civil aircraft unless it is in an airworthy condition.

3. HBWS Seeks exemption from the requirements of Section 91.121.

Section 91.121, entitled Altimeter settings, subsection (a), states the following, in part:

(a) Each person operating an aircraft shall maintain the cruising altitude or flight level of 

the aircraft, as the case may be, by reference to an altimeter that is set, when operating—

(1) Below 18,000 feet MSL, to—
7

(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 case of an aircraft not equipped with a radio, the elevation of the departure 

airport or an appropriate altimeter setting available before departure.

4. HBWS Seeks Exemption From The Requirements Of Section 91.171(b). 

Section 91.171, entitled Fuel requirements for flight in VFR conditions, subsection (b), states 

the following: 

(b) No person may begin a flight in a rotorcraft under VFR conditions unless (considering 

wind and forecast weather conditions) there is enough fuel to fly to the first point of 

intended landing and, assuming normal cruising speed, to fly after that for at least 20 

minutes.

5. HBWS Seeks Exemptions 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 the aircraft inspected as prescribe in subpart E of this part and shall between 

required inspections, except as provided in paragraph (c) of this section, have 

discrepancies repaired as prescribe in part 43 of this chapter [.]

6. HBWS Seeks Exemption From The Requirements Of Section 91.407(a)(1).

Section 91.407, entitled Operation after maintenance, preventive maintenance, rebuilding, 

or alteration, subsection (a)(1), states the following:

(a) No person may operate any aircraft that has undergone maintenance, preventive 

maintenance, rebuilding, or alteration unless –

(1) It has been approved for return to service by a person authorized under § 43.7 of 

this chapter [.]

7. HBWS Seeks Exemption From The Requirements Of Sections 91.409(a)(1) And 

91.409(a)(2).

Section 91.409, entitled Inspection, 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.
8

8. HBWS Seeks Exemption From The Requirements Of Section 91.417(a) and 91.417(b).

Section 91.417, entitled Maintenance records, subsection (a) and (b), state the following: 

(a) Except for work performed in accordance with §91.411 and §91.413, each registered 

owner or operator shall keep the following records for the periods specified in 

paragraph (b) of this section:

(1) Records of the maintenance, preventive maintenance, and alteration and 

records of the 100-hour annual, progressive, and other required or approved 

inspections, as appropriate, for each aircraft (including the airframe) and each 

engine, propeller, rotor, and appliance of an aircraft. The records must 

include—

(i) A description (or reference to data acceptable to the administrator) of the work 

performed; and

(ii) The date of completion of the work performed; and

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

return to service.

(2) Records containing the following information:

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

rotor.

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

and appliance.

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

required to be overhauled on a specified time basis.

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

inspection required by the inspection program under which the aircraft and its 

appliances are maintained.

(v) The current status of applicable airworthiness directive (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 defect 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.
9

C. The extent of relief HBWS Seeks And The Reason HBWS Seeks the Relief.

1. Extent of Relief HBWS Seeks And the Reason HBWS Seeks Relief from Section 61.113 (a) 

And (b).

Relief from Section 113(a) and (b) entitled Private pilot privileges and limitations: Pilot in 

Command, is requested to the extent necessary to allow a PIC holding a sport pilot or higher 

level pilot certificate, and either a current and valid airman medical certificate or valid Hawaii 

State Driver’s License, and who has completed the DJI Inspire 1 UAS training and currency 

requirements, to conduct the proposed UAS flight operations for compensation or hire. 

This relief is requested since the limitations set for in Section 61.113(a) and (b) state that a 

private pilot may, for compensation or hire, act as PIC of an aircraft in connection with any 

business or employment if- (1) The flight is only incidental to that business or employment; and 

(2) The aircraft does not carry passengers or property for compensation or hire.

As set for more fully below, HBWS submits that an equivalent level of safety will be 

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

demonstrated, through the DJI Inspire 1 UAS training and currency requirements, that the PIC is 

able to safely operate the DJI Inspire 1 UAS in a manner consistent with the operations 

specifications as describe in this exemption, including evasive and emergency maneuvers, as 

well as maintaining appropriate distances from people, vessels, vehicles and structures.

Further, HBWS submits that all flights of the DJI Inspire 1 UAS conducted by the PIC 

pursuant to the grant of this Petition- (1) will be incidental to HBWS’s business; and (2) will not 

carry passengers or property for compensation or hire.

2. Extent of Relief HBWS Seeks And the Reason HBWS Seeks Relief from Section 91.7(a).

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

extent required to allow HBWS to determine that the DJI Inspire 1 UAS is in an airworthy 

condition prior to every flight by ensuring that the UAS is in compliance with the DJI Inspire 

1 User Manual (Attachment C), and that the aircraft is in a condition for safe flight.

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

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

to every flight, HBWS will ensure that the DJI Inspire 1 is in an airworthy condition based 

upon a visual inspection, in order to determine that the UA and its components are in 

compliance with its type design and operating documents (i.e., the DJI Inspire 1 User 

Manual, GCS User Manual, and DJI Inspire 1 System safety guideline Manual), and that the 

aircraft can be operated safely pursuant to the conditions and limitations stated herein.

3. Extent of Relief HBWS Seeks And The Reason HBWS Seeks Relief From Section 91.121.

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

operations of the DJI Inspire 1 UAS, which utilized a barometric pressure sensor, GPS 

Equipment, and a radio communications telemetry data link to downlink altitude
10

information from the UA to the PIC at the GCS. HBWS seeks the requested relief because 

the DJI Inspire 1 UA does not utilize a typical barometric altimeter onboard that may be set 

as contemplated by Section 91.121. As more fully set forth below, an equivalent level of 

safety will be maintained since the DJI Inspire 1 UA is equipped with a barometric pressure 

sensor and GPS equipment which automatically ensures that a ground level pressure setting 

will be established prior to each flight, and provides the PIC with altitude information of the

UA on the heads-up display of the GCS.

4. Extent of Relief HBWS Seeks And the Reason HBWS Seeks Relief from Section 91.171(b).

Relief from Section 91.171(b) entitled Fuel requirements for flight in VFR conditions, is 

requested to the extent required to allow flights of the battery powered DJI Inspire 1 UAS

during daylight hours in Visual Meteorological Conditions (VMC), under Visual Flight Rules 

(VFR), for a total duration of 17 minutes to the first point of intended landing and, assuming 

normal cruising speed, to fly after that for at least five minutes. HBWS seeks the requested 

relief because without an exemption from section 91.171(b), the flight time duration of the 

battery powered DJI Inspire 1 UAS will severely constrain the practicality of an aerial 

acquisition and research flight operations that HBWS proposes to conduct pursuant to this 

Petition. 

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

DJI Inspire 1 User Manual, and HBWS’s proposed operating limitations, ensure that HBWS 

will safely operate the battery powered DJI Inspire 1 UA during daylight hours under VFR, 

with enough battery power to fly for a total duration of 17 minutes to the first point of 

intended landing and, assuming normal cruising speed, to fly after that for at least 5 

minutes.

5. Extent of Relief HBWS Seeks And the Reason HBWS 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, HBWS requests relief from these Sections 

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

more fully below, the DJI Inspire 1 UAS meets the conditions of Section 333 of the FMRA for 

operations without an airworthiness certificate. Accordingly, HBWS will use FAA qualified 

technicians to perform maintenance, alterations, or preventative maintenance on the UAS 

using the methods, techniques, and practices prescribed in the manufacturer’s maintenance 

manual. Furthermore HBWS will document and maintain all maintenance records for the 

DJI Inspire 1 UAS.

D. The Reasons Why Granting HBWS’s Request For Exemption 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 HBWS to safely, 

efficiently, and economically perform aerial acquisitions and research over rural areas of Hawaii, 
11

commercially, in support of an essential public utility. Additionally, use of the DJI Inspire 1 UAS 

will decrease congestion of the NAS, reduce pollution, and provide significant benefits to the 

economy, Notably, the benefits of HBWS’s proposed operations of the DJI Inspire 1 UAS will be 

realized without implicating any privacy issues.

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

HBWS submits this Petition to commercially operate the DJI Inspire 1 UAS and perform 

aerial acquisition and research throughout rural areas of the State of Hawaii, in support of 

government entities, land management, infrastructure management assessments, search 

and rescue operations, and reconnaissance operations during emergency situations. The DJI 

Inspire 1 UAS will provide safe, efficient, and economical aerial acquisition and research to 

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

The specific operations the HBWS will perform with the DJI Inspire 1 UAS demonstrate 

how the requested exemption will directly benefit the general public as a whole.

Land Management:

In the field of Land Management, HBWS’s operation of the DJI Inspire 1 UAS will be used 

to assess vegetation health including native and invasive plant monitoring. The HBWS is 

responsible for hundreds of acres of vital watershed lands on the island of Oahu. 

Specifically, HBWS’s ability to use the DJI Inspire 1 UAS to monitor and measure vegetation 

growth and soil erosion through aerial photos and videos. This ability to collect data during 

all seasons, will provide invaluable data for land and soil management, which is costly using 

conventional aircraft. The capability of the DJI Inspire 1 UAS to utilize the high definition 

video camera and high definition photography, will allow for detailed analysis and recording, 

necessary to determine land erosion, perform flood mapping and provide critical 

information for land management.

Emergency Response:

In the field of Emergency Response, HBWS’s operation of the DJI Inspire 1 will be used 

to assess conditions and formulate accurate damage assessments to critical public utility 

infrastructure following extreme weather events such as Tropical Storms, Hurricanes and 

Tsunamis.

2. The Public Will Benefit from Decreased Congestion of The NAS.

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

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

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

allowing the use of a DJI Inspire 1 UAS would reduce the amount of manned aircraft in the 

NAS, reduce noise and air pollution, as well as increase the safety of life and property in the 

air and on the ground.

Furthermore, by reducing the number of manned aircraft in the NAS, congestion around 

airports caused by arriving and departing aircraft will be reduced. The DJI Inspire 1 UAS 
12

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 DJI Inspire 1 UAS.

Conducting aerial acquisitions with the DJI Inspire 1 UAS, instead of manned aircraft, will 

greatly benefit the public by drastically reducing the level of air and noise pollution 

generated during traditional aerial survey flight operations. By using battery power and 

electric motors, the DJI Inspire 1 UAS produces no air pollution, and is the most viable 

environmentally conscious alternative to the cabin class, six cylinder internal combustion 

twin engine aircraft that are typically utilized for aerial acquisitions, while burning 

approximately 20-30 gallons per hour of leaded aviation fuel. The DJI 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 an internal combustion engine.

By using the DJI Inspire 1 UAS to perform aerial acquisitions, the substantial risk to life 

and property in the air and on the ground, which is usually associated with traditional 

manned aircraft operations, will be substantially reduced or completely eliminated. Aside 

from the lack of flight crew members located onboard the aircraft, the DJI Inspire 1 UA 

(weighing approximately 6.7 pounds at its maximum gross weight with a diameter of 26 

inches, and with no fuel on board), has less physical potential for collateral damage to life 

and property on the ground, and in the air, compared to the manned aircraft that typically 

conduct 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).

4. Performing Aerial Acquisition Operations With the DJI Inspire 1 UAS will Benefit the 

Economy.

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

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

DJI Inspire 1 UAS will allow United Sates based entities, like HBWS, to remain competitive 

and contribute to growth of the U.S. economy. Specifically, with the rising cost of leaded 

aviation fuels and the Environmental Protection Agency (“EPA”) regulatory action phasing 

out leaded aviation fuels, U.S. owned and operated companies must adopt new and 

alternative technology in order to remain competitive. Operating the battery powered DJI 

Inspire 1 UAS is one such technology that not only allows companies greater operational 

flexibility compared to manned aircraft, but provides such flexibility without the high 

operational cost of a traditional manned aircraft.

5. There Are No Privacy Issues.

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

previously, HBWS’s proposed operation of the DJI Inspire 1 UAS will no implicate any privacy 

issues. Specifically, the DJI Inspire 1 UAS will be operated only over HBWS owned lands and 

in accordance with the Federal Aviation Regulations, including the minimum altitude 

requirements of 14 C.F.R. §91.119. Most significantly, the DJI Inspire 1 UA will not be 
13

operated closer than 500 fee to any person, vessel, vehicle or structure, which is not directly 

involved in the operation.

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 HBWS Seeks Exemption.

1. Reasons Why the DJI 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 geographical area associated 

with the unmanned aircraft and its proposed flight operations, HBWS’s operation of the DJI 

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.—Not withstanding 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 require 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—

i. 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

ii. 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, HBWS submits that the DJI Inspire 1 UAS can operate safely in 

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

Inspire 1 UAS; (b) the pilot certification requirement; and (c) the specific operating limitations.

(a) The Specifications Of The DJI Inspire 1 UAS demonstrate Its Safe Characteristics. 

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

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

operational capability.
14

i. Technical Specifications Of the DJI Inspire 1 UAS.

The technical specifications of the DJI Inspire 1 UAS are set forth in the DJI Inspire 

1 User and Safety Manual, attached hereto as attachment A. Attachment A 

contains proprietary information and is to be held in a separate file pursuant to 14 

C.F.R §11.35(b)

ii. The DJI Inspire 1 UAS Autonomous Flight And Navigation Modes Enable The UAS 

to Remain Within A Defined Operational Area.

The DJI Inspire 1 UAS may be operate in either the semi-autonomous or fully 

autonomous flight modes. In its basic configuration, the DJI Inspire 1 UAS 

autonomous flight mode features include a GPS position and altitude Hold, and 

Return To Home (RTH) functions. While utilizing the GPS Position and Altitude 

Hold feature, the UA will automatically hold its position, altitude and heading. 

The RTH function commands a direct route to the original point of launch, 

where the UA will perform an autonomous landing.

A complete description of the GPS Position and Hold function of the DJI Inspire 1 

UAS is provided in the DJI Inspire 1 User Manual, attached here to as 

Attachment A. Attachment A contains proprietary information and is to be held 

in a separate file pursuant to 14 C.F.R. §11.35(b).

iii. The DJI Inspire 1 UAS Is Designed For Automatic Return To Home Or Auto-Land 

In The Event Of Loss Of The Control Link or Navigation.

According to the manufacturer of the DJI Inspire 1 UAS, in the unlikely event of a 

low battery condition or loss of control link, the UA will automatically land or 

return to the point of launch. An altitude threshold can be programmed, so that 

the UA will not exceed a preset altitude.

Through the GCS, the PIC may select whether the UA will return to the point of 

launch or automatically land in the unlikely event of the loss of the control link. 

If the automatic landing feature is selected, the UA will begin a slow, safe 

automatic descent to landing if the control link is lost. Through feedback via onboard inertia sensors, the UA motors are turned off and the rotors stop 

spinning, when the UA touches down upon landing.

Upon a loss of the control link, if the return to point of launch is selected, the 

UA will begin a return to the point of launch, in a direct line. Once the UA 

returns to the point of launch, it will hover to begin the manual landing process, 

or, if the control link has not been reestablished, the UA will automatically land. 

If the control link is reestablished during a loss of control link situation, the PIC 

may begin to manually control the UA.

Additionally, the PIC will receive visual alerts at the GCS in the event of a 

degradation of the GPS signal or control link. If less than six GPS satellites are 

within range of the DJI Inspire 1 UAS, the PIC will receive a visual “Low GPS 
15

Warning”, which will also disable the GPS position and hold feature, as well as 

the RTH feature.

Likewise, the DJI Inspire 1 UAS will provide a visual warning to the PIC at the GCS 

if the control link is lost, while the UA enters failsafe mode and either begins to 

return to the point of launch, or automatically lands, depending upon the PIC’s 

previous settings. Once the control link is reestablished, the PIC will be notified 

through visual alerts at the GCS.

A description of the fail-safe system of the DJI Inspire 1 UAS is attached hereto 

as Attachment A. Attachment A contains proprietary information and is to be 

held in a separate file pursuant to 14 C.F.R §11.35(b).

iv. The DJI Inspire 1 GCS And Its Operation.

A complete description of the operation and specifications of the DJI Inspire 1 

UAS GCS and flight control software is provided in the DJI Inspire 1 UAS User 

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

proprietary information, is attached hereto as Attachment A and is to be held in 

a separate file pursuant to 14 C.F.R §11.35(b).

(b) Flight Operations Of The DJI Inspire 1 UAS Are Limited To The Line Of Sight Of A 

Certificated Pilot in Command With A Safety Observer.

HBWS will only utilize certificated pilots who possess a valid and current airman 

medical certificate or Hawaii State Driver’s License, to act as pilot in command 

(PIC) of the DJI Inspire 1 UAS. Additionally, a safety observer will assist all pilots. 

(c) Flights Of The DJI Inspire 1 UAS Will Be Conducted Pursuant To Specific 

Operating Limitations.

In seeking this exemption, HBWS proposes to commercially operate the DJI 

Inspire 1 UAS for the special purpose of conducting aerial acquisitions over HBWS 

owned lands on the island of Oahu Hawaii pursuant to the following specific 

operating limitations:

1). Operations authorized by this grant of exemption are limited to the following 

aircraft described in the operator’s manual which is a quad rotor aircraft weighing 

less than 6.7 pounds; DJI Inspire 1 Unmanned Aircraft System. Propose operating 

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

2). The UA may not be flown at an indicated airspeed exceeding 30 knots.

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

level (AGL) as indicated by the procedures specified in the operator’s manual. All 

altitudes reported to ATC must be in feet AGL.
16

4). The UA must be operated within visual line of site (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 required by current limitations on their valid U.S Driver’s license.

5). All operations must utilize a visual observer (VO). The VO may be used to satisfy 

the VLOS requirement, as long as the PIC always maintains VLOS capability. The VO 

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

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

duration of the flight.

6).The operator’s manual and this grant of exemption must be maintained and 

made available to the administrator upon request. If a discrepancy exists between 

the conditions and limitations in the exemption and the procedures outlined in the 

operator’s manual, the conditions and limitations herein take precedence and must 

be followed. Otherwise, the operator must follow the procedures as outlined in the 

operator’s manual.

7). Prior to each flight the PIC must inspect the UAS to ensure it is in a condition for 

safe flight. If the inspection reveals a condition that affects the safe operation of 

the UAS, the aircraft is prohibited from operating until the necessary maintenance 

has been performed and the UAS is found to be in a condition for safe flight. The 

Ground Control Station must be included in the preflight inspection. All 

maintenance and alterations must be properly documented in the aircraft records

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 in accordance with the operator’s manual. The 

PIC who conducts the functional test flight must make an entry in the UAS aircraft 

records of the flight. The requirements and procedures for a functional test flight 

and aircraft record entry must be added to the operator’s manual.

9). The preflight inspection must account for all discrepancies, i.e. Inoperable 

components, items, or equipment, not covered in the relevant preflight inspection 

sections of the operator’s manual.

10). The operator must follow the manufacturer’s UAS aircraft component, 

maintenance, overhaul, replacement, inspection, and life limit requirements, with 

particular attention to flight critical components that may not be addressed in the 

manufacturer’s manuals.

11). HBWS must carry out their maintenance, inspections, and record keeping 

requirements in accordance with the operator’s manual. Maintenance, inspection, 

and alterations must be noted in the aircraft logbook, including total flight hours, 
17

description of work accomplished, and the signature of the authorized UAS 

technician or PIC returning the UAS to service.

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

System and Safety Bulletins.

13). HBWS maintenance personnel must make a record entry in the UAS logbook or 

equivalent document of the corrective action taken against discrepancies 

discovered between inspections.

14). The PIC must possess at least a sport pilot certificate and a third-class airman 

medical certificate or valid U.S. Driver’s License. The PIC must also meet the flight 

review requirements specified in 14 C.F.R §61.56 in an aircraft in which the PIC is 

rated on his or her pilot certificate.

15). The operator may not permit any PIC to operate unless that PIC has 

demonstrated, through the training and currency requirements set forth in the 

operator’s manual, that the PIC is able to safely operate the UAS in a manner 

consistent with how the UAS will be operate under this exemption including evasive 

and emergency maneuvers and maintaining appropriate distances from people, 

vessels, vehicles and structures.

16). 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. 

17). The UA may not operate within 5 nautical miles of the airport reference point 

as denoted on current FAA-published aeronautical chart.

18). The UA man 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.

19). If the UAS loses communication or loses its GPS signal, the UA must return to a 

pre-determined location within the private or controlled-access property and land, 

or be recovered in accordance with the operator’s manual

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

forecast weather conditions and assuming normal cruising speed) there is enough 

power to fly to the first point of intended landing prior to utilizing battery reserve 

power.

21).The operator must obtain an Air Traffic Organization (ATO) issued Certificate or 

Waiver or Authorization (COA) prior to conducting any operations above 200 feet 

AGL. This COA will also require the operator to request issuance of a Notice to 
18

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

prior to the operation.

22).Before conducting operations, the radio frequency spectrum used for operation 

and control of the UA must comply with the Federal Communications Commission 

(FCC) or other appropriate oversight agency requirements.

23). The documents required pursuant to 14 C.F.R 91.9 and 91.203 must be 

available to the PIC at the Ground Control Station of the UAS any time the 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 yield the right of way to all other manned 

aviation operations and activities at all times.

25). The UA may not be operated over congested or densely populated areas. 

These areas include but are not limited to yellow areas depicted on World 

Aeronautical Charts (WAC), Sectional Aeronautical Charts (Sectionals), or Terminal 

Area Charts (TAC). However, aeronautical charts may not reflect pertinent local 

information. Ultimately, it is the PIC’s responsibility to maintain the minimum safe 

altitudes required by §91.119

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

persons (persons other than the PIC or VO), vessels, vehicles, and structures unless:

a. Barriers or structures are present that sufficiently protect nonparticipating 

persons from 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 are within 500 feet of the UA, flight 

operations must cease immediately and/or;

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

owner/controller has granted permission and the PIC has made a safety assessment 

of the risk of operating closer to those objects and;

c. operations near the PIC or VO do not present an undue hazard to the PIC or VO, 

per §91.119(a)

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

with permission from the land owner/controller or authorized representative. 

Permission from land owner/controller or authorized representative will be 

obtained prior to the beginning of every flight.

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 
19

must be reported to the National Transportation Safety Board (NTSB) per 

instructions contained on the NTSB Web Site: www.NTSB.gov

2. Reason Why An Exemption From the Requirements of Section 61.113(a) And (b) Would 

Not Adversely Affect Safety.

HBWS submits that the equivalent level of safety established by Section 

61.113(a) and (b) will be maintained because no PIC will be allowed to operate the DJI 

Inspire 1 UAS unless that PIC has demonstrated, through the DJI Inspire 1 UAS training 

and currency requirements, that the PIC is able to safely operate the DJI Inspire 1 UAS in 

a manner consistent with this exemption, including evasive and emergency maneuvers 

and maintaining appropriate distances from people, vessels, vehicles and structures.

Considering HBWS’s proposed area of operations and the operating limitations 

set forth above; the parallel nature of sport pilot aeronautical knowledge requirements 

to those of commercial pilot requirements (See Exemption No. 11062); and the 

airmanship skills necessary to safely operate the DJI Inspire 1 UAS, HBWS submits that 

the additional manned airmanship experience of a commercially certificated pilot would 

not correlate to the airmanship skills necessary for HBWS’s specific proposed flight 

operations.

Additionally, the FAA has previously granted relieve from Section 61.113(a) and 

(b) specific to UAS, in circumstances similar, in all material respects, to those presented 

herein (e.g. Exemptions Nos. 11062, 11063, 11064, 11065, 11066, 11080, 11109, 11110, 

11112, 11136, 11138, 11461)

As in Exemption No. 11109, HBWS will not allow any PIC to operate the DJI 

Inspire 1 UAS unless that PIC has demonstrated through the DJI Inspire 1 UAS training 

and currency requirements, that the PIC is able to safely operate the DJI Inspire 1 UAS in 

a manner consistent with this exemption. Including evasive and emergency maneuvers 

and maintaining appropriate distances from people, vessels, vehicles and structures.

3. 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, HBWS will ensure that the DJI Inspire 1 UAS is in an 

airworthy condition based upon the aircraft’s conformity to its type design, including 

compliance with its operating documents (i.e., the DJI Inspire 1 User Manual and the DJI 

Inspire 1 System User/Safety Manual, and that the UAS in in a condition for safe flight, 

as stated in the conditions and limitations contained herein.

Notably, the similar DJI Phantom 2 UAS was the subject of a previous Grant of 

Exemption from Section 91.7(a) (Exemption No. 11153). Additionally, the FAA has 

previously granted relief from Section 91.7(a) specific to UAS, in circumstances similar, 

in all material respects, to those presented herein (e.g. Exemption Nos. 11062, 11063, 

11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112, 11136, 11138, 11461)
20

4. Reasons Why An Exemption From The Requirements Of Section 91.121 Would Not 

Adversely Affect Safety.

The equivalent level of safety established by Section 91.121 will be maintained 

because the altitude information of the DJI Inspire 1 UAS will be provided to the PIC via 

GPS equipment and a radio communications telemetry data link, which downlinks from 

the UAS to the GCS for active monitoring of the flight path and altitude. The altitude 

information, combined with HBWS’s operation of the DJI Inspire 1 UAS visual line of 

sight, at or below 400 feet AGL, will ensure a level of safety equivalent to Section 

91.121. That altitude information will be generated by GPS equipment installed 

onboard the aircraft. Prior to each flight, a zero altitude initiation point is automatically 

established by the UAS. 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, 

11110, 11112, 11136, 11138, 11461)

5. Reasons Why An Exemption From The Requirements of Section 91.171(b) Would No 

Adversely Affect Safety.

A grant of this exemption would ensure an equivalent level of safety established 

by 14 C.F.R Section 91.171(b) as a result of (1) the technical specifications of the DJI 

Inspire 1 UAS; (2) the limitations on the proposed flight operations; and (3) the location 

of the proposed flight operations. Accordingly, HBWS will ensure that it will safely 

operate the battery powered DJI Inspire 1 UA during daylight VMC conditions, under 

VFR, with enough battery power to fly for a total during of 17 minutes to the first point 

of intended landing and, assuming normal cruising speed, to fly after that for at least 

five minutes.

Similar to the FAA’s Grant of Exemption No. 11109, HBWS hereby submits that 

the technical specifications of the DJI Inspire 1 UAS; the limitations on the proposed 

flight operations; and the location of the proposed operations, will ensure an equivalent 

level of safety established by 14 C.F.R Section 91.171(b). Furthermore, an equivalent

level of safety will be ensured as the DJI Inspire 1 UAS provides visual warnings to the 

PIC at the GCS when the UA battery power is low.

Significantly, previous exemptions granted by the FAA concerning Section 

91.171 establish that safety is not adversely affected when the technical characteristics 

and operating limitations of the UAS are considered. Relief has been granted for 

manned aircraft to operate at less than the minimums prescribed in Section 91.171, 

including Exemption Nos. 2689, 5745, and 10650. Moreover, the FAA has previously 

granted relief from Section 91.171 Specific to UAS, in circumstances similar, in all 

material respects, to those presented herein (e.g. Exemption Nos. 8811, 10808, 10673, 

11042, 11062, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11136, 11138, 

11461).
21

6. Reasons Why An Exemption From The Requirements of Sections 91.405(a), 91.407(a)(1), 

91.409(a)(1) & (a)(2), And 91.417(a) & (b) Would Not Adversely Affect Safety.

In seeking this exemption, HBWS submits that an equivalent level of safety with 

regard to the regulatory maintenance and alteration requirements established by 

Sections 91.405(a), 91407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) will be met 

because HBWS will use FAA qualified technicians to perform maintenance, alterations, 

or preventive maintenance on the UAS using the methods, techniques, and practices 

prescribed in the manufacturer’s user/safety manual. Furthermore, HBWS will 

document and maintain all maintenance records from the DJI Inspire 1 UAS.

Since the DJI Inspire 1 UAS will be inspected as prescribed by the manufacturer’s 

user/safety manual, HBWS will maintain the equivalent level of safety established by 

Sections 91.405(a) 91.409(a)(1), and 91.409(a)(2). The DJI Inspire 1 System user/Safety 

Manual sets forth suggested requirements for the UA, including preflight inspections, as 

well as scheduled maintenance after every 50 flight hours.

Likewise, the exemption sought will not adversely affect safety because HBWS 

will use FAA qualified technicians to perform maintenance, alterations, or preventive 

maintenance on the UAS using the methods, techniques, and practices prescribed by 

the manufacturer’s user/safety manual. The DJI Inspire 1 System user/safety Manual 

procedures for inspection, firmware upgrades, motor testing, and more replacement.

A complete description of the DJI Inspire 1 UAS maintenance requirements is set 

forth in the DJI Inspire 1 System user/safety Manual, attached hereto as Attachment A. 

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

pursuant to 14 C.F.R §11.35(b).

Furthermore, the exemption sought would maintain an equivalent level of 

safety established by Sections 91.407, 91.417(a) and 91.417(b), because all maintenance 

of the DJI Inspire 1 UAS will be performed by FAA qualified technicians, which will 

document and maintain records of the UAS.

Significantly, previous exemptions granted by the FAA concerning the DJI Inspire 

1 UAS and Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2) and 91.417(a) & (b) 

establish that safety is not adversely affected when the technical characteristics and 

operating limitations of the UAS are considered.

In consideration of HBWS’s proposed operating limitations, the DJI Inspire 1 

User Manual, and the technical aspects of the DJI Inspire 1 UAS, HBWS submits that 

safety will not be adversely affected by granting exemption from 14 C.F.R. Section 

s91.405(a), 91.407(a)(1) and (a)(2), 91.409(a)(2), and 91.417(a) and (b). The FAA has 

previously granted relief specific to UAS in circumstances similar, in all material respects, 

to those presented herein (e.g. Exemption Nos. 11062, 11063, 11064, 11065, 11066, 

11067, 11080, 11109, 1110, 11112, 11136, 11148, 11461)

7. The FAA May Prescribe Any Other Conditions For Safe Operation.

In accordance with Section 333 of the FAA Modernization and Reform Act of 

2012 (FMRA) and 14 C.F.R §21.16 entitled Special Conditions, HBWS requests that the 

FAA prescribe special conditions for the intended operation of the DJI Inspire 1 UAS, 
22

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 §§61.113(a) & (b), 91.7(a), 91.121, 91.171(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) 

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

Such special conditions will permit HBWS’s safe operation of the UA for the 

limited purpose of conduction aerial acquisitions over certain rural areas of the United 

States for compensation or hire. FMRA Section 333 sets forth the requirements for 

considering whether a UAS will create a hazard to users of the NAS or the public. Or 

otherwise pose a threat to national security; and further, provides the authority for such 

UAS to operate without airworthiness certification in accordance with any requirements 

that must be established for the safe operation of the UAS in The NAS

Likewise, the Administrator may prescribe special conditions pursuant to 14 

C.F.R §21.16, for operation of the DJI Inspire 1 UAS, since the airworthiness regulation 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 HBWS’s intended operation of the DJI Inspire 1 

UAS, which contain such safety standards that the Administrator finds necessary to 

establish a level of safety equivalent to that established by 14 C.F. R. Part 21, Subpart H, 

and 14 C.F.R Sections 61.113(a) & (b), 91.7(a), 91.121, 91.171(b), 91.405(a), 

91.407(a0(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 

HBWS Seeks Exemption:

HBWS seeks exemption from the requirements of 14 C.F.R Sections 45.23 61.113(a)&(b), 

91.7(a), 91.121, 91.171(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b).

A Brief Description Of The Nature Of The Exemption HBWS Seeks:

This exemption will permit HBWS to commercially operate an Unmanned Aircraft System (UAS) 

for the purpose of conducting aerial acquisitions, research and inspections over certain rural 

areas of the United States.
23

G. Any Additional Information, Views, or Arguments Available To Support HBWS’s Request.

This Petition is made pursuant to the FAA Modernization and Reform Act of 2012 

(FMRA) Section 333, which directs the Secretary of Transportation to determine if certain UAS 

may operate safely in the NAS. As such, HBWS’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, HBWS will operate the DJI Inspire 1 UAS safely in the NAS, 

without creating a hazard to users of the NAS, or the public, or otherwise pose a threat to 

national security.

CONCLUSION

As set forth herein, HBWS 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 JDI Inspire 1 UAS commercially, without an airworthiness certificate, for the limited

purpose of conducting aerial acquisitions over certain rural areas of the United States for 

compensation or hire. 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 HBWS to safely, efficiently, and economically operate the 

DJI Inspire 1 UAS commercially within the NAS.

Wherefore, in accordance with the Federal Aviation Regulations and FAA Modernization 

and Reform Act of 2012, Section 333, HBWS respectfully requests that the Administrator grant 

this Petition for an exemption from the requirements of 14 C.F.R Sections 45.23, 61.113(a) & (b), 

91.7(a), 91.121, 91.171(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)2, and 91.417(a) & (b), and 

permit HBWS to operate the DJI Inspire 1 UAS commercially for the purpose of conducting aerial 

acquisitions, research and inspections over certain rural areas of the United States.

Dated June 30, 2015.

Respectfully submitted,

Aaron Woods, GIS Analyst

Board of Water Supply

630 South Beretania St.

Honolulu, HI. 96843

808-748-5256

awoods@hbws.org
24

Appendix A

Maintenance Manual

INSPIRE 1

V1.0 2015.2

To ensure that your aircraft continues to offer optimal performance and to ensure flight safety, it is 

recommended that comprehensive maintenance be performed after every 200 flights or 50 flight 

hours. This manual is intended to help users maintain their aircraft and maximize its continued 

reliability.

I. Checking the Battery

1. Check the battery for damage and deformities. If there are any signs of damage to the 

battery, stop using it and discharge the battery to 10% or below for disposal. Do not disassemble 

the battery for any reason.

2. Check the battery pins and rub them clean with an eraser if any residue is observed. This will 

help to ensure a more reliable connection.

3. Check the metal battery power connectors for damage. If the connectors appear burnt, try to 

clear them. This can be done by inserting a piece of sandpaper (1mm thick) into the connectors 

to polish the metal.

4. Check the contact pins in the battery compartment to ensure that the pins are clear. They 

should be able to establish easy contact with the battery connectors and should not be bent.

5. Check the electrodes on the battery. If they appear burnt, polish them with sandpaper. If 

there is serious erosion, send the battery in for repairs.

6. Check the plastic components of the battery bracket to see it is in good condition and that all 

screws are secure. This prevents the battery from becoming loose during flight.

7. Check the power cables between the arms and the center plate, if the cables are worn, 

contact DJI to arrange repairs.

8. For long term storage, please refer to the “Intelligent Flight Battery Safety Guidelines” and 

check the battery once a month to prevent the battery cell from being damaged.

9. Run the DJI Pilot App to confirm that all battery cells are at similar voltage levels and stay at 

the same level when the battery is fully charged. If all cells maintain voltage levels above 3.7V 

but any cell is 0.2V higher or lower than the others, contact DJI for analysis. You can also check 

the battery cell warning history. If any warning are reported, contact DJI.

II. Checking the Transformation System

1. Check the servomotor cables for wear. Also confirm that the connection points are still in 

good condition.

2. Check the lead screws and contact DJI Support to arrange repairs if any bending or damage is 

discovered. Clean the lead screws with WD-40 spray if they show signs of rust.

3. Listen to the servomotors during the transformation, if there is abnormal noise, it may

indicate that the servomotors worn.

4. After the landing gear rises, check the lead screws and bearings. If any dirt or dust is found, 

clean and grease the bearings.

5. Check the lead screws. If there is any scratches, dents, or plastic particles underneath them, 

contact DJI Support to arrange repairs.
25

III. Checking the Aircraft

1. Confirm that all the screws are still adequately tightened.

2. Check the aircraft for breaks or damage. If there is any reason to believe that detectable 

damage might affect flight safety, consult with DJI Support.

3. Check the carbon tubes of the arms for damage.

4. Check the dampers on the landing gears. If they are loose, secure them with 502 glue.

5. Ensure that there are no obstacles on or around the

GPS module or around the antennas on the landing gear. Remove any obstacles (such as tapes 

with conductive material) that might affect or block the signal.

6. Check that the right and left landing gear rest at the same tilt angle.

To ensure that your aircraft continues to offer optimal performance and to ensure flight safety, 

it is recommended that comprehensive maintenance be performed after every 200 flights or 50 

flight hours. This manual is intend to help users maintain their aircraft and maximize its 

continued reliability.

IV. Checking the Motors

1. Check the rotors to confirm that they have not become loose.

2. Detach the propellers and start the motors. Listen carefully. If there is any abnormal noise, 

please replace the motors. This may be a sign that the bearings have been worn out.

3. Detach the propellers and start the motors. Carefully examine the edge of the rotor and 

confirm that the shaft is perfectly centered on the motor. Check for any abnormal or excessive 

vibration. If any problems are detected, contact DJI Support to order replacement motors.

4. Check for deformities by confirming that the gap between the motor and motor base is even. 

If not contact DJI Support to order replacement motors.

5. Ensure that the screws used to secure the motor base are tight and the plastic components 

around the motors are in good condition. If not please tighten the screws and contact DJI to 

repair any broken plastic components.

V. Checking the Propellers

1. Check the propellers. If there is any bending, breakage or cracking on a propeller, do not use 

it.

2. Attach the propeller to the motor, turn on the aircraft, and place it on the ground. Stand 1 

meter away from the aircraft and observe the rotating propellers. If you can see two distinct 

propeller outline layers, when looking at a spinning propeller from the side, this propeller is 

damaged and should not be used.

VI. Checking the IMU

1. Open DJI Pilot app to check the condition of the IMU and perform an advanced IMU 

calibration. Please place the aircraft in a cool environment and on a flat, stable surface (if the 

landing gear is damaged, support the aircraft with four objects of equal height). Do not touch 

the craft during the calibration.

2. Turn on the aircraft and listen for any abnormal noise or vibration from the fan located on the 

front of the aircraft. If any irregularity is detected, replace the fan.

VII. Checking the Control and Video Transmission System

1. Check the 4 antennas on the landing gear to ensure that they are secure. Also check for any 

bending or damage.

2. Check the antennas of the remote controller for damage
26

3. Check the neck strap for damage or wear, replace if necessary.

VIII. Checking the Gimbal and Camera

1. The quick-mount connector for the camera is a particularly vulnerable component. If the 

gimbal fails to initialize when turned on, fails to work after initialization, or fails to transmit 

video to the app (while OSD data is displayed), the quick-mount connector may be worn. In this 

case, replace the rubber mat, circuit board, and/or connector on the gimbal quick-mount.

2. Check the metal contacts on the quick mount connector board, if any contact is bent, replace 

the quick-mount connector.

3. Check the contact pins on the quick-mount connector board, if there is any dirt, rub it clean 

with an eraser. If any contact pins are worn out it should be replaced.

4. Confirm that the gimbal is able to properly stabilize itself. If its stabilizing performance 

deteriorates, contact DJI to arrange repairs.

5. Listen for any abnormal noise from the fan when the gimbal is turned on. This may indicate 

unusual vibration and the fan should be replaced.

IX. Checking the Vision Positioning System

1. Check the lens of the camera. If any dirt or residueis detected, gently clean the lens.

2. Check for and remove objects that might block the sensors.

3. Ensure that the Vision Positioning System is securely installed on the aircraft.

4. Detach the propellers and turn on the aircraft. Hold the aircraft 1-2 meters above a surface 

with rich patterns, under good lighting conditions. Change the Flight Mode switch to P Mode on 

the controller and check the DJI Pilot app. If the app displays an altitude value and indicates that 

P-OPTI mode is active, the Vision Positioning System should function normally.

The content is subject to change.

Download the latest version from

http://www.dji.com/product/inspire-1/download

Support Center Contact Info:

http://www.dji.com/support

© 2015 DJI. All Rights Reserved.
27

Appendix B

INSPIRE 1

Safety Guidelines

V1.0 2014.12

Reading Inspire 1 Manuals

The following tutorials and manuals have been produced to help you make full use of your DJI Inspire 1:

1. In The Box

2. Disclaimer and Warning

3. Intelligent Flight Battery Safety Guidelines

4. INSPIRE 1 Safety Guidelines

5. INSPIRE 1 Quick Start Guide

6. INSPIRE 1 User Manual

Check all of the included parts listed in the In The Box document. Read the Disclaimer and Warning,

Intelligent Flight Battery Safety Guidelines, and INSPIRE 1 Safety Guidelines before flight. Then prepare 

for your first flight by using the INSPIRE 1 Quick Start Guide and watching all of the tutorial videos. If you 

have questions, refer to the INSPIRE 1 User Manual for more comprehensive information. Experienced 

users, particularly those who have previously used DJI products, may choose to skip to the Inspire 1 

Quick Start Guide to begin preparing for flight.

Individual Parts

Remote Controller

1. Linking is required if you wish to replace your remote controller or receiver, or add a new remote 

controller. Refer to the user manual for more information about how to link the aircraft.

2. If the remote controller is powered on and has not been used for 5 minutes, it will sound an alert. 

After 10 minutes it will automatically power off. Move the sticks or perform some other action to cancel 

the alert.

3. A Slave remote controller cannot be linked with the aircraft and cannot control the aircraft’s flight. 

You may change it to a Master remote controller via the DJI Pilot app, and then link it to the aircraft to 

control flight.

4. Ensure the Mobile Device Holder is firmly in place and does not slip.

5. For the GPS in the remote controller to function properly, and the Dynamic Home Point to be 

accurate ensure the DJI logo is facing the sky and keep the remote controller away from any metal 

objects.

6. Repair or replace the remote controller if damaged. A damaged remote controller antenna will greatly 

decrease performance.

7. When on the go, you may charge the remote controller from the aircraft’s Intelligent Flight Battery.

Camera

1. Photos or videos cannot be transmitted or copied from the camera if the Intelligent Flight Battery is 

powered off.
28

2. Be sure to power off the Intelligent Flight Battery correctly, otherwise your camera parameters will 

not be saved and any recorded videos may be damaged.

3. Test the camera by shooting a few test images to check that it is operating correctly before shooting 

important pictures.

4. Respect the privacy of others when using the camera. Make sure you comply with local privacy laws, 

regulations and moral standards.

5. Check camera settings before use to make sure you can adjust them to fit your needs.

Gimbal

1. The gimbal and gimbal connector are very delicate. Handle with care and do not touch the gimbal 

connector, as any damage will cause it to function abnormally.

2. A gimbal motor error may occur if: (1) The aircraft is placed on uneven ground or other objects 

obstruct the gimbal’s full range of motion, or (2) The gimbal has undergone an excessive impact, e.g. a 

collision.

Please only takeoff from flat, open areas and protect the gimbal after powering up.

3. Hold the gimbal firmly when detaching or reattaching it, so it does not drop.

4. Do not add any payloads to the gimbal, as this may cause the gimbal to function abnormally, or even

lead to motor damage.

5. Precision elements in the gimbal may be damaged by a collision or impact, which will cause the 

gimbal to function abnormally.

Compass

1. Ensure the compass is calibrated before every flight. Failure to calibrate may lead to a poor flight 

performance or even failure.

2. DO NOT calibrate your compass where there is a chance of strong magnetic interference. This 

includes areas where there are massive metal objects, parking structures, and steel reinforcements 

underground, or under bridges.

3. DO NOT carry ferromagnetic materials with you during calibration, such as keys or mobile phones.

4. The compass should always be recalibrated when moving from indoor spaces to outdoor spaces.

5. If the rear LED shows a solid red light, compass calibration has failed. Please recalibrate.

6. After successful calibration, the compass may become abnormal when you put the aircraft on the 

ground. This is because of magnetic interference that may be underground. Move the aircraft to another 

location and try again.

Parameter Settings

The Inspire 1 features a built-in flight control system to make operation as safe as possible. However, it 

is good practice to remove all propellers before switching it on for calibration or changing other 

parameter settings.

Battery

Refer to the Intelligent Flight Battery Safety Guidelines and battery sticker for usage and maintenance 

information.

Storage and Transportation

1. Store the Intelligent Flight Battery and remote controller in a cool, dry place away from direct 

sunlight, to ensure the built-in LiPo battery does not overheat. Recommended storage temperature: 

between 22°C and 28°C for storage periods of more than three months. Never store in environments 

outside the temperature range of -20°C to 45°C.
29

2. Do not allow the camera to come into contact with, or become immersed in, water or other liquids. If 

it gets wet, wipe dry with a soft, absorbent cloth. Turning on an aircraft that has fallen into water may 

cause permanent component damage. Do not use substance containing alcohol, benzene, thinners or 

other flammable substances to clean or maintain the camera. Do not store the camera in humid or dusty 

areas.

3. Always keep all parts out of the reach of children, as the cables, straps or small parts may be 

dangerous if swallowed. If swallowed, go to the hospital immediately.

4. Detach the gimbal from the Inspire 1 when storing for a long period of time or transporting over long 

distances. Also replace the Gimbal Cover when storing.

Maintenance and Upkeep

1. Check every part of the aircraft if it is violently impacted. If you have any problems or questions, 

please contact a DJI authorized dealer.

2. Old, chipped, or broken propellers or motors should never be used.

3. Regularly check the Battery Level Indicators to see the current battery level and overall battery life. 

When the battery life reaches 0%, it can no longer be used.

4. After every 50 hours of flight time, DJI recommends you perform a thorough inspection of your 

Inspire 1 and all of its parts and components to ensure the safe operation of your aircraft.

EN

Flight Environment Requirements

1. Do not use the aircraft in severe weather conditions. These include wind speed exceeding 10m/s, 

snow, rain, smog, heavy wind, hail, lightning, tornado or hurricane.

2. Do not use the aircraft in dust or sandstorms.

3. Fly in open areas, as tall buildings or steel structures may affect the accuracy of the onboard compass 

and block the GPS signal.

4. Keep the aircraft away from obstacles, people, animals, high voltage power lines, trees, and bodies of 

water when in flight.

5. Avoid interference between the remote controller and other wireless equipment. Make sure to turn 

off the Wi-Fi on your mobile device.

6. Do not fly near areas with magnetic or radio interference. These include but are not limited to: high 

voltage lines, large scale power transmission stations, mobile base stations and broadcasting towers.

Failing to do so may compromise the transmission quality of this product, cause remote controller and 

video transmission errors may affect flight orientation and location accuracy. The aircraft may behave 

abnormally or fall out of control in areas with too much interference.

7. P mode is unavailable in polar zones. Users can use ATTI mode instead.

8. Do not fly the aircraft within no-fly zones specified by local laws and regulations.

Flight Warnings

Failsafe and Return to Home

1. Return to Home will not work if the GPS signal is insufficient or GPS is not active.

2. Press the RTH Button on the remote controller to bring the aircraft back to the Home Point instead of 

turning off the remote controller.

3. Tall buildings may adversely affect the Failsafe function. Please adjust the aircraft location, altitude 

and speed while returning home to avoid obstacles.

4. Make sure to always fly the aircraft within the transmission range of the remote controller.

5. When updating the Home Point, do not block the GPS signal of the remote controller and ensure the 

new Home Point is correct on the live map.
30

6. Do not update the Home Point near tall buildings, as the GPS may be blocked and lead to an incorrect 

location being stored.

7. Only use the Failsafe and Return to Home functions in case of emergency, as they may be affected by 

the weather, the environment, or any nearby magnetic fields.

Low Battery

1. When the Critical Battery Level Warning activates and the aircraft is descending automatically, you 

may push the throttle upward to hover the aircraft and navigate it to a more appropriate location for 

landing.

2. When battery warnings are triggered, please bring the aircraft back to the Home Point or land to 

avoid losing power during flight.

Vision Positioning System

1. The Vision Positioning System cannot work properly over surfaces that do not have pattern variations.

The effective altitude for Vision Positioning System to function correctly is less than 2.5 meters.

2. Vision Positioning System may not function properly when the aircraft is flying over water.

3. Vision Positioning System may not be able to recognize patterns on the ground in low light conditions 

(less than 100 lux).

4. Keep your pets away from the aircraft when Vision Positioning System is activated, as the sonar 

sensors emit high frequency sound that is only audible to some pets.

5. Note that Visual Positioning System may not function properly when the aircraft is flying too fast or 

too low.

EN

Transformation Function

1. Ensure the landing gear is lowered before landing.

2. Stay away from the aircraft when it is transforming to prevent injury.

3. DO NOT attempt to catch the aircraft, as the landing gear will lower if the Visual Positioning system

detects an object and may cause injury.

4. Keep the aircraft arms clean, otherwise transformation may be affected.

5. Never apply lubricants to aircraft arms.

Others

1. If you are using a phone as your mobile display device, be sure to continue flying safely if you receive 

an incoming call.

2. Land as soon as possible if there is an alert shown on the DJI Pilot app.

3. Upon landing, power off the aircraft first, then switch off the remote controller.

Preflight Checklist

1. Check that all parts are in good condition. Do not fly with aging or damaged parts.

2. Remote controller, Intelligent Flight Battery and mobile device are all fully charged.

3. Propellers are mounted correctly and securely.

4. Lens is clear.

5. Micro-SD card has been inserted, if necessary.

6. Gimbal is functioning as normal.

7. Gimbal is correctly attached to the aircraft.

8. Motors can start and are functioning as normal.

9. The DJI Pilot app can connect to the camera and all firmware has been updated to the latest version.

EN