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 AIRCR** **AFT 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

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-5256 awoods@hbws.org2 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...............................................................................................................273 **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 S pa ce 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 Fl ight Rules
VLOS Visual Line of Site
VMC Visual Meteorological Conditions
VO Visual Observer
VTOL Vertical Takeoff and Landing4 **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 PETITION ER**  Honolulu Board of Water Supply (hereinafter referred to as “HBWS”) was founded in 1929 and manages the municipal water resources and distribution system s 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
c ommunities 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 System s: 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 St ation (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, here by 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, H BWS’s use of the DJI Inspire 1 meets the conditions of FMRA Section 333 and therefore, will not require an airworthiness certificate in accordance wit h 14 C.F.R. Part 21, Subpart H. Accordingly, H BWS 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.
H BWS submits that the requested relief is proper since the equivalent level of safety will be ensured. H BWS 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, H BWS 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 H BWS 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 pro posed UAS flight operations. H BWS 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.
H BWS 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, H BWS 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.
H BWS 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 H BWS’s operation of the DJI Inspire 1 UA withi n visual line of sight, at or below 400 feet AGL, will ensure a level of safety equivalent to Section 91.121. Additionally, H BWS seeks an exemption from the requirements of Section 91.171(b), entitled Fuel requirements for flight in VFR conditions

. H BWS submits that safety will not be affected by operations of the DJI Inspire 1 UA during daylight hours under V isual F light R ules (FVR) and V isual M eteorological Conditions (VMC), with enough battery power to fly for a total of 17 minutes to the first point of intended landing and, assuming normal c r u ising speed, to fly after that for at least five minutes.6

In accordance with 14 C.F.R 11.81, H BWS provides the following information in support of its petition for exemption:
A. **Name and Addres s of the**  **Petitioner** : Honolulu Board of Water Supply 630 South Beretania St. Honolulu, HI. 9 6843 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 Bereta nia St. Honolulu, HI. 9 6843 808

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**B. The Specific Sections of 14 C.F.R. from which**  **H BWS Seeks Exemption.**  **1. H**  **BWS 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. H**  **BWS 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. H**  **BWS Seeks exemption from the requirements of Section 91.121.**
Section 91.121 , entitled Altimeter settin gs, subsection (a), states the following, in part: (a) Each person operating a n aircraft shall maintain the cru ising 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 curren t re ported 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 a n 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. H**  **BWS Seeks Exemption From The Requirements Of Section 91.171(b).** 
Section 91.17 1, 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 th e first point of intended landing and, assuming normal cruising speed, to fly after that for at least 20 minutes.

5. **H BWS 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 disc repancies repaired as prescribe in part 43 of this chapter [.]

**6. H**  **BWS Seeks Exemption**  **From The Requirements Of Section 91.40 7**  **(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 servic e by a person authorized under § 43.7 of this chapter [ .]

**7. H**  **BWS 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 unles s, 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. **H BWS Seeks Exemption From The Require**  **ments 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, a nd 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 ap proving 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 engine s, 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**  **H BWS Seeks And T** **he Reason H**  **BWS Seeks the Relief.**

**1. Extent of**  **Relief H**  **BWS Seeks And the Reason H**  **BWS Seeks Reli ef 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, a nd 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 reli ef 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 busin ess or employment; and (2) The aircraft does not carry passengers or property for compensation or hire. As set for more fully below, H BWS 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, H BWS submits that all flights of the DJI Inspire 1 UAS conducted by the PIC pursuant to the grant of this Peti tion

- (1) will be incidental to H BWS’s business; and (2) will not carry passengers or property for compensation or hire.
**2. Extent of Reli**  **ef H**  **BWS S** **eeks And the Reason H**  **BWS 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 H BWS to determine that the DJI Ins p ire 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. H BWS 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, H BWS 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. Exten** **t of Relief**  **H BWS Seeks And The Reason**  **H BW** **S 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 altitude10 information from the UA to the PIC at the GCS. H BWS 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 m ore 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 prio r 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**  **H BWS Seeks And the Reason**  **H BWS 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 V isual M eteorological Conditions (VMC), under V isual F light R ules (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. H BWS 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 H BWS 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 H BWS’s proposed operating limitations, ensure that H BWS 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**  **H BWS Seeks And the Reason**  **H BWS 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 , H BWS 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 wi t hout an airworthiness certificate. Accordingly, H BWS will use FAA qualified tec hnicians to perform maintenance , alteration s, or preventative maintenance on the UAS using the methods, techniques, and practices prescribed in the manufacturer’s maintenance manual. Furthermore H BWS will document and maintain all maintenance records for the DJI Inspire 1 UAS.

D. **The Reasons Why Gr anting**  **H BWS’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 H BWS to safely, efficiently, and economically perform aer ial 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
ec onomy, Notably, the benefits of H BWS’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

.
H BWS submits this Petition to comm ercially 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 H BWS 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, H BWS’s operation of the DJI Inspire 1 UAS will be used to assess vegetation health including native and invasive plant monitoring. The H BWS is responsible for hundreds of a cres of vital watershed lands on the island of Oahu. Specifically, H BWS’s ability to use the DJI Inspire 1 UAS to monito r 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 manageme nt.
Emergency Response: In the field of Emergency Response, H BWS’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 UAS12 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 handle d by air traffic control during the ground, takeoff, departure, arrival, and landing ph ases 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 l evel 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 cyl inder internal combustion twin engine aircraft that are typically utilized for aerial acquisitions, while burning approximately 20

-30 gallons per h our 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 prop erty 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 Operation s**  **With the DJI Inspire 1 UAS will B enefit 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 entitie s, like H BWS, 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 a nd 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 aircra ft, 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, H BWS’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 H BWS 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 be13 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 S** **afety, Or How The Exemption Would Provide A Level Of Safety At Least Equal To That Provided By The Rule From**  **Which H**  **BWS 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, H BWS’s operation of the DJI Inspire 1 UAS meets the conditions of FMRA Section 333, and will not requi re 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 certific ate 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 syste m. In seeking this exemption, H BWS 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 spe cific operating limitations.

(a) **The Specifications Of T** **he DJI Inspire 1 UAS demonstrate Its S** **afe 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 . Attac hment 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 p osition 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 rou te 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 ).
i ii

. 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 on

board inertia sen sors, 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 GPS15 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, dependin g 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 contain s 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 p rovided 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 T** **he DJI Inspire 1 UAS Are Limited To The Line Of Sight Of A Certificated Pilot in Command With A Safety Observer** 

.
H BWS will only utilize certificated pilots who pos s ess a valid and current airman medical certificate or Hawaii State Driver’s License, to a ct 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, H BWS proposes to commercially operate the DJI Inspire 1 UAS for the special purpose of conduct ing aerial acquisitions over H BWS owned lands on the island of Oahu Hawaii pursuant to the following specific operating limitations: 1). Operations authorized by this grant of e xemption are limited to the following aircraft described in the operator’s manual which is a quad rotor aircraft weighing less tha n 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 condit ions 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 fligh t. 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 Contro l 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 requireme nts 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 com ponents that may not be addressed in the manufacturer’s manuals.
11). H BWS must carry out their maintenance, inspections, and record keeping requirements in accordance with the operator’s manual. Maintenance, inspection, and alterations must be note d 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). H BWS 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 p ilot 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 wil l 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 opera tions 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

- publis hed aeron aut ical 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 Wai ver 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 to18 Airman (NOTAM) not more than 72 hours in advance, but not less than 48 hours prior to the operatio n. 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 de picted 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 min imum 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 s ufficiently 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 with in 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 operatin g 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/controlle r 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 boundar ies 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. Accidents19 must be reported to the National Transportation Safety Board (NTSB) per instructions contained on the NTS B 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.**

H BWS 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 requireme nts, 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 H BWS’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 sa fely operate the DJI Inspire 1 UAS, H BWS submits that the additional manned airmanship experience of a commercially certificated pilot would not correlate to the airmanship skills necessary for H BWS’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, 111 38, 11461) As in Exemption No. 11109, H BWS 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 U AS in a manner consistent with this exemption. Including evasive and emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles and structures.

3. **Reason s**  **Why An Exemption From The Requirements Of Section 91.7(a) Would Not Adve**  **rsely Affect Safety**

.

The equivalent level of safety established by Section 91.7(a) will be maintained because prior to every flight, H BWS 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 a ll 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 S** **a fety** 

.

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 H BWS’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 Requireme nts 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 lim itations on the proposed flight operations; and (3) the location of the proposed flight operations. Accordingly, H BWS will ensure that it will safely operate the battery powered DJI Inspire 1 UA during daylight VMC conditions, under VFR, with enough batt ery 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, H BWS hereby submits that the tech nical 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 adverse ly 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 106 50. 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, 110 66, 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, H BWS 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 H BWS 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, H BWS 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, H BWS will maintain the equivalent level of safety established by Sections 91.405(a) 91.409(a)(1), and 91.409(a)(2). The DJI In spire 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 H BWS wil l 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 procedu res 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 mai ntenance 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 H BWS’s proposed operating limitations, the DJI Inspi re 1 User Manual, and the technical aspects of the DJI Inspire 1 UAS, H BWS 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 ha s 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, H BWS 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 H BWS’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 n ational 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 beca use 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 H BWS’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**  **H BWS 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 H**  **BWS 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 Arg**  **uments Available To Support H**  **BWS’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 , H BWS’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 th e 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, H BWS 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, H BWS seeks an exemption pursuant to 14 C.F.R. § 11.61 and Section 333 of the FAA Modernization and Reform Act of 2012 (FM RA), 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 grantin g 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 H BWS 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, H BWS 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 H BWS to operate the DJI Inspire 1 UAS commercially for the purpose of conducting aeri al 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.org24 **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 discha rge 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 met al 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 pin s in the battery compartment to ensure that the pins are clear. They should be able to establish easy contact with t he battery connectors and should not be bent. 5. Check the electrodes on the battery. If they appear burnt, polish t hem with sandpaper. If there is serious erosion, send the battery i n for repairs. 6. Check the plastic co mponents of the battery bracket to see it is in good co ndition 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 plat e, if the cables are worn, contact DJI to arrange repairs. 8. For long term storage, p lease refer to the “Intelligent Flight Battery S afety 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 batte ry cell warning history. If any warning are reported, contact DJI. **II. Checking the Transformation System** 1. Check the servomoto r 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 t he 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, chec k the lead screws and bearings. If any d irt or dust is found, clean and grease the bearings. 5. Check the lead screws. If there is any scratches, dents, or plastic particles undernea th 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 aro und the antennas on the landing gear. Remove an y obstacles (such as tapes with conductive material) that might affect or block the signal. 6. Check that the right an d left landing gear rest at the same tilt angle. To ensure that your aircraft continues to offer optimal performan ce and to ensure flight safety, it is recommended that comprehensive maintenance be performe d after every 200 flights or 50 flight hours . This manual is intend to help users maintain their airc raft and maximize its continued reliabil ity. **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 deformi ties 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 loo king 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 a dvanced IMU calibration. Please place the aircraft in a cool environ ment 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 a ircraft. If any irregu larity 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 damage26

3. Check the neck st rap for damage or wear, replace if necessary. **VIII. Checking the Gimbal and Camera** 1. The quick

- moun t connector for the camera is a particularly vuln erable component. If the gimbal fails to initialize when turned o n, fails to work after initialization, or fai ls 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 gimba l is able to properly stabilize itself. If its stabil izing performance deteriorates, contact DJI to arrange repairs. 5. Listen for any a bnormal noise from the fan when the gimbal is turned on. This may indic ate 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 residue is detected, gently clean the le ns. 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 m eters 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 Pi lot app. If the app displays an altitude value an d indicates that P

- OPTI mode is active, the Vision Pos itioning System should function n ormally. 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 befo re flight. Then prepare for your first flight by using the INSPIRE 1 Quick Start Guide and watching all of t he tutorial videos. If you have questions, refer to the INSPIRE 1 User Manual for more comprehensive information. Experienced users, particularly th ose who have previously used DJI products, may choose to sk ip 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, i t will sound an alert. After 10 minutes it will automatically pow er 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 t hen 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 Dyn amic Home Point to be accurate ensure the DJI logo is facing th e 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 th e Intelligent Flight Battery is powered off.28

2. Be sure to power off the Intelligent Flight Battery correctly, otherwise your came ra pa rameters 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, regulation s 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 c are and do not touch t he 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 g round or other objects obstruct the gimbal’s full range of motion, or (2) The gimbal has undergone an exces sive 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 impa ct, which will cause the gimbal to function abnormally. Compass 1. Ensure the compass is calibrated before every flight. Failure to cali brate may lead to a poor flight performance or even failure. 2. DO NOT calibrate your compass where there is a chance of strong magnetic in terference. 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 w hen you put the aircraft on the ground. This is because of magnetic interference that may be undergroun d. 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 s afe as possible. However, it is good practice to remove all propellers before switching it on for calibrat ion 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 con troller in a cool, dry p lace away from direct sunlight, to ensure the built

- in LiPo battery does not overheat. Recommend ed storage temperature: between 22°C and 28°C for storage periods of more than three months. Never store in environments outside the tem perature 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 permane nt component damage. Do not use substance containing alco hol, 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 ca bles, 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 an y problems or questions, please contact a DJI authorized dealer. 2. Old, chipped, or broken propellers or motors should never be used. 3. Regula rly 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 thorou gh inspection of your I nspire 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 wi nd 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 po wer lines, trees, and bodies of water when in flight. 5. Avoid interference between the remote controller and other wireless equip ment. Make sure to turn off the Wi

- Fi on your mobile device. 6. Do not fly near areas with magnetic or radio interference. These inclu de 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 produ ct, 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 th e RTH Button on the remote controller to bring the aircraft ba ck 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 ret urning 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 remot e controller and ensure the new Home Point is correct o n the live map.30

6. Do not update the Home Point near tall buildings, as the GPS may be b locked and lead to an incorrect location being stored. 7. Only use the Failsafe and Return to Home functions in case of emerge ncy, as they may be affected by the weathe r, 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 groun d 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 so me 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. N ever 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. Up on 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 fu nctioning as normal. 9. The DJI Pilot app can connect to the camera and all firmware has been updated to the latest version. **EN**