November 14, 2015

Attn: U. S. Department of Transportation 

Docket Operations 

West Building Ground Floor, Room w12-140

1200 New Jersey Ave, SE Washington, DC 20590 

RE: Discovery Drones, LLC. REQUESTS AN EXEMPTION FROM THE REQUIREMENTS OF TITLE 14 

OF THE CODE OF FEDERAL REGULATIONS SECTIONS 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 

91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), AND 91.417(a) & (b) CONCERNING COMMERCIAL 

OPERATION OF DJI INSPIRE 1 UNMANNED AIRCRAFT SYSTEMS PURSUANT TO SECTION 333 

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

Douglass Chouinard, CEO Discovery Drones, LLC. PO BOX 531 HOWELL, MI 48844 248.496.3436 

dchouinard3@yahoo.com
AGL-Above Ground Level 

AOI-Area of Interest

ATC-Air Traffic Control Air Traffic Organization Aerial Vehicle 

CFR-Code of Federal Regulations

COA- Certificate of Authorization 

FAA-Federal Aviation Administration 

FAR-Federal Aviation Regulation 

GCS-Ground Control Station 

GPSL-Global Positioning System Loss of Link National Airspace System Notice to Airman 

PIC-Pilot In Command

FMRA-FAA Modernization and Reform Act of 2012 

SO-Safety Observer

SOP-Standard Operating Procedures

UA-Unmanned Aircraft

Unmanned Aircraft System

VFR-Visual Flight Rules
Visual Line of Site

VMC-Visual Meteorological Conditions

VTOL-Vertical Takeoff and Landing 

Discovery Drones, LLC. hereafter referred to as Discovery Drones, LLC. seeks exemption from the 

requirements of 14 C.F.R §§ 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 

91.409(a)(1) & (a)(2), and 91.417(a) & (b), to operate an Unmanned Aircraft System (DJI Inspire 13) 

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

permit Discovery Drones, LLC.to operate an Unmanned Aircraft System (UAS) for the commercial 

purpose of conducting aerial video and photography of construction sites, residential and commercial real 

estate, civil landscapes and events over certain areas of the United States. 

INTRODUCTION AND INTERESTS OF THE PETITIONER 

Discovery Drones, LLC. has for over thirty-five years provided their clients (which include private sector 

businesses and non-profits, along with local state and federal agencies) with expertise and knowledge in 

video and multimedia marketing, advertising, public relations and training using advanced technologies 

and solutions. Discovery Drones, LLC. has worked on thousands of productions over the past 35 years in 

all types of locations with a perfect client and employee safety record. In the past we have supplied our 

clients aerial video and photography using commercial aircraft. The objective of Discovery Drones, LLC.

and our Unmanned Aircraft System (DJI INSPIRE 1 aerial operations is to provide a more affordable, 

high-quality production system for a variety of governmental, commercial, public, and residential uses, 

specifically targeting 

• Construction sites before and after 

• Appraisals 

• Real-estate marketing 

• Economic development 

• Civic landmarks 

• Special event coverage 
• Private and governmental training My staff has safely flown small RC electric quadcopters 

recreationally for approximately 2 years without incident. BACKGROUND Unmanned Aircraft 

Systems: DJI Inspire 13, UAS Discovery Drones, LLC. seeks an exemption to operate DJI 

Inspire 1system for compensation or hire within the NAS. The DJI Inspire 1is vertical takeoff and 

landing (VTOL) Unmanned Aircraft (UA) with a Ground Control Station (GCS) utilizing electronic 

tablet or smart phone systems. The DJI Inspire 1has a maximum gross weight of approximately 

2.8 lb. while having a diagonal dimension of 23.2”, a maximum speed of approximately 16.4’fps 

and a maximum flying height of 400'. The DJI Inspire 1is equipped with four main rotors; driven 

by Lithium Polymer battery powered electric motors. 

The DJI Inspire 1that will be operated by Discovery Drones, LLC. will be registered in accordance with 49 

U.S.C. 44103, Registration of Aircraft, as well as 14 C.F.R Part 47, Aircraft Registration, and marked in 

accordance with 14 C.F.R. Part 45, Identification and Registration Marking. 

BASIS FOR PETITION 

Petitioner, Discovery Drones, LLC., pursuant to the provisions of the Federal Aviation Regulations (14 

C.F.R. § 11.61) and the FAA Modernization and Reform Act of 2012 (FMRA), Section 333, Special Rules 

for Certain Unmanned Aircraft Systems, hereby petitions the Administrator to commercially operate the 

DJI Inspire 13, UAS in the National Airspace System (NAS), and for an exemption from the requirements 

of 14 C.F.R §§ 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), 

and 91.417(a) & (b). 

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

aircraft and its operation, Discovery Drones, LLC. operation of DJI Inspire 1UAS 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, Discovery Drones, LLC. requests relief from Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) 

& (a)(2), and 91.417(a) & (b), as these sections set forth requirements for maintenance that only apply to 

aircraft with an airworthiness certificate. 

Discovery Drones, LLC. submits that the requested relief is proper since an equivalent level of safety will 

be ensured. Discovery Drones, LLC. will use experienced personnel or technicians to perform 

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

practices prescribed in the operating documents (i.e., Monthly Maintenance Log, and DJI Inspire 

1Instruction Manual). Furthermore, Discovery Drones, LLC. will document and maintain all maintenance 

records for the DJI Inspire 1UAS. 
Relief from certain requirements of Section 61.113(a) and (b), entitled Private pilot privileges and 

limitations: Pilot in command, is requested by Discovery Drones, LLC.to the extent necessary to allow a 

Pilot in Command (PIC) holding a private pilot or higher level certificate, as well as an airman medical 

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

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

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

vessels, vehicles and structures. 

Discovery Drones, LLC. seeks relief from Section 91.7(a), 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, Discovery Drones, LLC. submits that they will ensure that the DJI Inspire 1 UAS is in 

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

operating documents (i.e., Monthly Maintenance Log, and DJI Inspire 1Instruction Manual), and that the 

aircraft are in a condition for safe flight. 

Discovery Drones, LLC. also seeks an exemption from the requirements of Section 91.121, entitled 

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

However, altitude information of the DJI Inspire 1 UAS will be provided to the PIC via Global Positioning 

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

the GCS for active monitoring of the flight path. This altitude information, combined with Discovery 

Drones, LLC.’s operation of the DJI Inspire 1UAS within visual line of sight, at or below 400 feet AGL, will 

ensure a level of safety equivalent to Section 91.121. 

Additionally, Discovery Drones, LLC. seeks an exemption from the requirements of Section 91.151(b), 

entitled Fuel requirements for flight in VFR conditions. Discovery Drones, LLC. submits that safety will not 

be affected by operation of the DJI Inspire 1 UAS during daylight hours in visual meteorological conditions 

(VMC) under visual flight rules (VFR), with enough battery power to fly for a total duration of 

approximately 23 minutes. Battery power indicators are also able to show exactly how much battery 

power is left, as well as how much time is needed to return safely back to point of take off. 
In accordance with 14 C.F.R. § 11.81, Discovery Drones, LLC. provides the following information in 

support of its petition for exemption: 

A. Name And Address Of The Petitioner. 

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

Douglass Chouinard CEO Discovery Drones, LLC.PO BOX 531HOWELL, MI 48844 248.496.3436 

dchouinard3@yahoo.com

B. The Specific Sections of 14 C.F.R. From Which Discovery Drones, LLC. seeks 

Exemption. 

1. Discovery Drones, LLC. Seeks Exemption from The Requirements of Section 61.113(a) And (b). 

Section 61.113, entitled Private pilot privileges and limitations: Pilot in command, subsections (a) and (b) 

prescribe the following, in relevant part: 

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

is carrying passengers or property for compensation or hire; nor may that person, for compensation or 

hire, act as PIC of an aircraft. 

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

or employment if—

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

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

2. Discovery Drones, LLC. 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. Discovery Drones, LLC. seeks Exemption From The Requirements Of Section 91.121. 

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

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

the case may be, by reference to an altimeter that is set, when operating--
(1) Below 18,000 feet MSL, to--

(i) The current reported altimeter setting of a station along the route and within 100 nautical miles of the 

aircraft; 

(ii) If there is no station within the area prescribed in paragraph (a)(1)(i) of this section, the current 

reported altimeter setting of an appropriate available station; or 

(iii) In the case of an aircraft not equipped with a radio, the elevation of the departure airport or an 

appropriate altimeter setting available before departure. 

4. Discovery Drones, LLC. seeks Exemption From The Requirements Of Section 91.151(b). 

Section 91.151, entitled Fuel requirements for flight in VFR conditions, subsection (b), states the 

following: 

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

forecast weather conditions) there is enough fuel to fly to the first point of intended landing and, assuming 

normal cruising speed, to fly after that for at least 20 minutes. 

5. Discovery Drones, LLC. seeks Exemption from The Requirement of Section 91.405(a). 

Section 91.405, entitled Maintenance required, subsection (a), states the following: Each owner or 

operator of an aircraft—

(a) Shall have that aircraft inspected as prescribed in subpart E of this part and shall between required 

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

prescribed in part 43 of this chapter[.] 

6. Discovery Drones, LLC. 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. Discovery Drones, LLC. seeks Exemption from The Requirements Of Sections 91.409(a)(1) And 

91.409(a)(2). 

Section 91.409, entitled Inspections, subsection (a), states the following: (a) Except as provided in 

paragraph (c) of this section, no person may operate an aircraft unless, within the preceding 12 calendar 

months, it has had --

(1) An annual inspection in accordance with part 43 of this chapter and has been approved for return to 

service by a person authorized by § 43.7 of this chapter; or 

(2) An inspection for the issuance of an airworthiness certificate in accordance with part 21 of this 

chapter. 

8. Discovery Drones, LLC. seeks Exemption from The Requirements Of Sections 91.417(a) And 91.417(b). 

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

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

operator shall keep the following records for the periods specified in paragraph (b) of this section: 

(1) Records of the maintenance, preventive maintenance, and alteration and records of the 100-hour, 

annual, progressive, and other required or approved inspections, as appropriate, for each aircraft 

(including the airframe) and each engine, propeller, rotor, and appliance of an aircraft. The records must 

include--

(i) A description (or reference to data acceptable to the Administrator) of the work performed; and 

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

(iii) The signature, and certificate number of the person approving the aircraft for return to service. 

(2) Records containing the following information: 

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

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

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

on a specified time basis. 
(iv) The current inspection status of the aircraft, including the time since the last inspection required by 

the inspection program under which the aircraft and its appliances are maintained. 

(v) The current status of applicable airworthiness directives (AD) and safety directives including, for each, 

the method of compliance, the AD or safety directive number and revision date. If the AD or safety 

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

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

and currently installed engines, rotors, propellers, and appliances. 

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

(1) The records specified in paragraph (a)(1) of this section shall be retained until the work is repeated or 

superseded by other work or for 1 year after the work is performed. 

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

aircraft at the time the aircraft is sold. 

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

retained until the defects are repaired and the aircraft is approved for return to service. 

C. The Extent of Relief Discovery Drones, LLC. seeks And The Reason Discovery Drones, 

LLC. seeks The Relief. 

1. Extent of Relief Discovery Drones, LLC. seeks And The Reason Discovery Drones, LLC. seeks Relief 

from Section 61.113(a) And (b). 

Relief from Section 61.113(a) and (b) entitled Private pilot privileges and limitations: Pilot in command, is 

requested to the extent necessary to allow a PIC holding a private pilot or higher level certificate, as well 

as a current and valid airman medical certificate, and who has met certain flight-hour and currency 

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

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

may, for compensation or hire, act as PIC of an aircraft in connection with any business or employment if: 

(1) The flight is only incidental to that business or employment; and (2) The aircraft does not 

carry passengers or property for compensation or hire. 
As set forth more fully below, Discovery Drones, LLC. submits that an equivalent level of safety will be 

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

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

the DJI Inspire 1UAS in a manner consistent with the operations specifications as described in this 

exemption, including evasive and emergency maneuvers, as well as maintaining appropriate distances 

from people, vessels, vehicles and structures. 

Further, Discovery Drones, LLC. 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 Discovery Drones, LLC.’s business; and (2) 

will not carry passengers or property for compensation or hire. 

2. Extent Of Relief Discovery Drones, LLC.Seeks And The Reason Discovery Drones, 

LLC.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 

Discovery Drones, LLC.to determine that the DJI Inspire 1 UAS are in airworthy condition prior to every 

flight by ensuring that the UAS is in compliance with the operating documents (i.e., DJI Inspire 1

Instruction Manual). 

Discovery Drones, LLC. seeks the requested relief because the DJI Inspire 1 UAS do not require an 

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

LLC. will ensure that the DJI Inspire 1 UAS are in airworthy condition based upon its compliance with the 

operating documents (i.e., DJI Inspire 1 Instruction Manual) prior to every flight, and further, determine 

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

3. Extent of Relief Discovery Drones, LLC. seeks And The Reason Discovery Drones, LLC.

Seeks Relief From Section 91.121. 

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

DJI Inspire 1 UAS, which utilize a barometric pressure sensor, GPS equipment, and a radio 

communications telemetry data link to downlink altitude information from the UA to the PIC at the ground 

control station (GCS). Since the FAA requires that any altitude information concerning UAS operations be 

reported to air traffic control (ATC) in feet above ground level (AGL), Discovery Drones, LLC. seeks the 

requested relief because the DJI Inspire 1UA’s altimeter may be set on the ground to zero feet AGL, 

rather than the local barometric pressure or field altitude, before each flight. 
Considering the limited altitude of the proposed operations, relief from 14 CFR 91.121 is sought to the 

extent necessary to comply with the applicable conditions and limitations stated below. As more fully set 

forth herein, an equivalent level of safety will be maintained since the DJI Inspire 1UAS are equipped with 

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

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

the UA on the heads-up display of the GCS. 

4. Extent Of Relief Discovery Drones, LLC.Seeks And The Reason Discovery Drones, 

LLC.Seeks Relief From Section 91.151(b). 

Relief from Section 91.151(b) entitled Fuel requirements for flight in VFR conditions, is requested to the 

extent required to allow flights of the battery powered DJI Inspire 1UAS during daylight hours in visual 

meteorological conditions (VMC), under visual flight rules (VFR), for a total duration of 23 minutes. 

Discovery Drones, LLC. seeks the requested relief because without an exemption from Section 

91.151(b), the flight time duration of the battery powered DJI Inspire 1UAS will severely constrain the 

practicality of any aerial video or still photo flight operations that Discovery Drones, LLC. proposes to 

conduct pursuant to this Petition. 

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

operating documents, and Discovery Drones, LLC.’s proposed operating limitations, ensure that 

Discovery Drones, LLC. will safely operate the battery powered DJI Inspire 1UAS during daylight hours in 

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

for a total duration of 23 minutes. 

5. Extent of Relief Discovery Drones, LLC. seeks And The Reason Discovery Drones, LLC. 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, Discovery Drones, LLC. requests relief from these Sections because the 

DJI Inspire 1 UAS does not require airworthiness certificates. As set forth more fully below, the DJI Inspire 

1 UAS meet the conditions of FMRA Section 333 for operation without an airworthiness certificate. 

Accordingly, Discovery Drones, LLC. will use trained technicians to perform maintenance, alterations, or 

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

operating documents (i.e., DJI Inspire 1Instruction Manual). Furthermore, Discovery Drones, LLC. will 

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

D. The Reasons Why Granting Discovery Drones, LLC. request Would be in the Public Interest; That Is, 

How It Would Benefit The Public As A Whole. 
Granting the present Petition will further the public interest by allowing Discovery Drones, LLC.to safely, 

efficiently, and economically perform aerial video and photography of construction sites, real estate, 

events and civic landscape over certain areas of the United States. 

Additionally, use of the DJI Inspire 1UAS will decrease congestion of the NAS, reduce pollution, and 

provide significant benefits to the economy. Notably, the benefits of Discovery Drones, LLC.’s proposed 

operation of the DJI Inspire 1UAS will be realized without implicating any privacy issues. 

1. The Public Will Benefit from Decreased Congestion Of The NAS. 

The DJI Inspire 1UAS are battery powered and serve 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 1UAS would 

reduce the amount of manned aircraft in the NAS, reduce noise and air pollution, as well as increase the 

safety of life and property in the air and on the ground. 

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

airports caused by arriving and departing aircraft will be reduced. The DJI Inspire 1UAS do not require an 

airport to takeoff or land. Likewise, a reduction of manned aircraft conducting aerial video and 

photography missions would result in fewer aircraft that must be handled by air traffic control during the 

ground, takeoff, departure, arrival, and landing phases of flight operations. 

2. The Public Will Benefit from The Safety And Efficiency Of The DJI Inspire 1UAS. 

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

the public by drastically reducing the levels of air and noise pollution generated during traditional aerial 

video and still photography flight operations. By using battery power and electric motors, the DJI Inspire 

1UAS produce no air pollution, and is the most viable environmentally conscious alternative to the cabin 

class, six cylinder internal combustion engine aircraft that are typically utilized for aerial video and 

photography, while burning approximately 20-30 gallons per hour of leaded aviation fuel. The DJI Inspire 

1UAS, while reducing the carbon footprint of aerial acquisitions, also eliminates noise pollution, as the 

UAS are propelled by battery powered electric motors, rather than an internal combustion engine. 

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

air and on the ground, which is usually associated with traditional manned aircraft flight operations, will be 

substantially reduced or completely eliminated. Aside from the lack of flight crew members located 

onboard the aircraft, the DJI Inspire 1UAS (weighing approximately 2.8 pounds at their maximum gross 

weight with diagonal dimension of 23.2 inches, and with no fuel on board), has less physical potential for 
collateral damage to life and property on the ground, and in the air, compared to the manned aircraft that 

typically conduct similar operations (weighing approximately 6,000 pounds with a wingspan of 

approximately 42 feet, a length of 34 feet, and a fuel capacity of 180 gallons). 

3. Performing Aerial Video and Photography Operations With The DJI Inspire 1UAS Will Benefit The 

Economy. 

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

manned aircraft to conduct similar aerial operations. As such, operation of the DJI Inspire 1UAS will allow 

United States based companies, like Discovery Drones, LLC., to remain competitive and contribute to 

growth of the U.S. economy. Specifically, with the rising cost of aviation fuel and the Environmental 

Protection Agency (“EPA”) regulatory actions phasing out leaded aviation fuels, U.S. owned and operated 

companies must adopt new and alternative technology in order to remain competitive. Operating the 

battery powered DJI Inspire 1UAS is one such technology that not only allows companies greater 

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

operational cost of a traditional manned aircraft. 

By operating the DJI Inspire 1UAS, companies such as Discovery Drones, LLC., can remain competitive 

and profitable, and therefore, provide greater job stability to employees and contractors, which will 

ultimately contribute to growth of the U.S. economy. Improved financial performance of U.S. companies, 

through commercial use of the DJI Inspire 1UAS, provides a stable workforce that increases consumer 

spending; improves local, state, and federal tax revenues; and allows companies to invest in research 

and development in order to remain competitive both in the United States and abroad. 

4. There Are No Privacy Issues. 

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

Discovery Drones, LLC.’s proposed operation of the DJI Inspire 1UAS will not implicate any privacy 

issues. Specifically, the DJI Inspire 1UAS will be operated only in compliance with operating documents 

(i.e., Discovery Drones, LLC. aerial Operations Manual, Monthly Maintenance Log, and DJI Inspire 

1Instruction Manual) which requires property owner involvement as well as local law enforcement 

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

requirements of 14 C.F.R. § 91.119. 

E. The Reasons Why Granting The Exemption Would Not Adversely Affect Safety, Or How The 

Exemption Would Provide A Level Of Safety At Least Equal To That Provided By The Rule From Which 

Discovery Drones, LLC. aeeks Exemption. 
1. Reasons Why The DJI Inspire 1 UAS Meet the Conditions Of The FAA Modernization and Reform Act 

of 2012 (FMRA) Section 333. 

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

aircraft and its operation, Discovery Drones, LLC.’s operation of the DJI Inspire 1 UAS meet the 

conditions of FMRA Section 333, and will not require an airworthiness certificate in accordance with 14 

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

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

requirements for considering whether a UAS will create a hazard to users of the NAS or the public, or 

otherwise pose a threat to national security. Specifically, FMRA Section 333 states the following, in part: 

(a) In General, notwithstanding any other requirement of this subtitle, and not later than 180 days after the 

date of enactment of this Act, the Secretary of Transportation shall determine if certain unmanned aircraft 

systems may operate safely in the national airspace system before completion of the plan and rulemaking 

required by section 332 of this Act or the guidance required by section 334 of this Act. 

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

Secretary shall determine, at a minimum--

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

capability, proximity to airports and populated areas, and operation within visual line of sight do not create 

a hazard to users of the national airspace system or the public or pose a threat to national security; and 

(2) whether a certificate of waiver, certificate of authorization, or airworthiness certification under section 

44704 of title 49, United States Code, is required for the operation of unmanned aircraft systems 

identified under paragraph (1). 

(c) Requirements for Safe Operation. --If the Secretary determines under this section that certain 

unmanned aircraft systems may operate safely in the national airspace system, the Secretary shall 

establish requirements for the safe operation of such aircraft systems in the national airspace system. 

In seeking this exemption, Discovery Drones, LLC. submits that the DJI Inspire 1 UAS can operate safely 

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

1UAS; (b) the pilot certification requirement; and (c) the specific operating limitations. 
a. The Specifications of The DJI Inspire 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. 

i. Technical Specifications of The DJI Inspire 1UAS. The technical specifications of the DJI Inspire 1 UAS 

are set forth by the DJI Inspire 1 User Manual.

ii. The DJI Inspire 1 UAS Global Positioning Modes Enable The UAS to Remain Within A Defined 

Operational Area. 

The DJI Inspire 1 UAS may be operated in both manual and global positioning flight modes. A complete 

description of the flight and navigational modes of the DJI Inspire 1UAS is provided at pages 11 of the DJI 

Inspire 1User Manual attached hereto as Appendix A. 

iii. The DJI Inspire 1UAS Are Designed for Automatic Return To Home Point Or Hover In The Event Of 

Loss Of The Control Link Or Navigation. 

When the Control Link is lost, the DJI Inspire 1UAS will remain stationary, in flight, for 3 seconds or more. 

If, after 3 seconds, the DJI Inspire 1UAS does not reacquire control link data from the GCS, the UAS will 

assume that the Control Link is lost and the will return to the home position (i.e., failsafe mode) via GPS, 

and will descend to the takeoff position and shutdown. 

A complete description of the Failsafe Functions of the DJI Inspire 1 UAS are set forth at pages 12 

through 14 of the DJI Inspire 1User Manual, attached hereto as Appendix A. 

iv. The DJI Inspire 1GCS and Its Operation. 

A complete description of the operation and specifications of the DJI Inspire 1GCS and flight control 

software is provided at pages 23 through 29 of the DJI Inspire 1User Manual. DJI Inspire 1User Manual is 

attached hereto as Appendix A. 

b. Flight Operations of DJI Inspire 1UAS Is Limited To The Line Of Sight Of A Certificated Pilot in 

Command With A Safety Observer. 

Discovery Drones, LLC. video production staff will be the only persons to act as a pilot in command (PIC) 

of the DJI Inspire 1 UAS. Additionally, a safety observer will assist him at all times during flight time. 

c. Flights of DJI Inspire 1 UAS Will Be Conducted Pursuant to Specific Operating Limitations. 
In seeking this exemption, Discovery Drones, LLC. proposes to commercially operate DJI Inspire 1UAS 

for the special purpose of conducting aerial video and photography over certain areas of United States, 

pursuant to the following specific operating limitations. 

1. Operations authorized by this grant of exemption will be limited to the following aircraft described 

in the operating documents, rotorcraft UAS weighing less than 55 pounds maximum gross weight: 

DJI Inspire 1 Unmanned Aircraft Systems. Proposed operations of any other aircraft will require a 

new petition or a petition to amend this grant. 

2. UAS operations under this exemption will be limited to conducting operations for the purpose of 

aerial video and photography. 

3. The UAS may not be flown at an indicated airspeed exceeding 20 knots. 

4. The UA must be operated at an altitude of no more than 400 feet above ground level (AGL), as 

indicated by the procedures specified in the operating documents unless a special request is 

made and approved by ATC. All altitudes reported to ATC must be in feet AGL. 

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

the PIC to be able to use human vision unaided by any device other than corrective lenses, as 

specified on the PIC’s FAA-issued airman medical certificate. 

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

7. Operations may utilize a safety observer (SO). The SO may be used to satisfy the VLOS 

requirement as long as the PIC always maintains VLOS capability. The SO and PIC must be able 

to communicate verbally at all times. Electronic messaging or texting is not permitted during flight 

operations. The PIC must be designated before the flight and cannot transfer his or her 

designation for the duration of the flight. The PIC must ensure that the SO can perform the 

functions prescribed in the operating documents. 

8. The SO must not perform any other duties beyond assisting the PIC with seeing and avoiding 

other air traffic and other ground based obstacles/obstructions and is not permitted to operate the 

camera or other instruments. 

9. The operating documents and the grant of exemption must be accessible during UAS operations 

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

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

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

precedence and must be followed. Otherwise, the operator must follow the procedures as 

outlined in its operating documents. The operator may update or revise its operating documents. 

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

documents to the Administrator upon request. The operator must also present updated and 

revised documents if it petitions for extension or amendment to the grant of exemption. If the 
operator determines that any update or revision would affect the basis upon which the FAA 

granted the exemption, then the operator must petition for amendment to its grant of exemption. 

The FAA’s UAS Integration Office (AFS-80) may be contacted if questions arise regarding 

updates or revisions to the operating documents. 

10. Prior to each flight the PIC must inspect the UAS to ensure that it is in a condition for safe flight. If 

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

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

found to be in a condition for safe flight. The Ground Control Station must be included in the 

preflight inspection. All maintenance and alterations must be properly documented in the aircraft 

records. 

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

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

flight. The PIC who conducts the functional test flight must make an entry in the aircraft records. 

12. The pre-flight inspection must account for all potential discrepancies, e.g. inoperable 

components, items, or equipment, not already covered in the relevant sections of the operating 

documents. 

13. The operator must follow the UAS manufacturer’s aircraft/component, maintenance, overhaul, 

replacement, inspection, and life limit requirements. 

14. The operator must carry out its maintenance, inspections, and record keeping requirements, in 

accordance with the operating documents. Maintenance, inspection, alterations, and status of 

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

in service, description of work accomplished, and the signature of the authorized person returning 

the UAS to service. 

15. Each UAS operated under this exemption must comply with all manufacturer Safety Bulletins. 

16. The authorized person must make an entry in the aircraft record of the corrective action taken 

against discrepancies discovered between inspections. 

17. The PIC must possess at least a private pilot certificate and at least a current third- class medical 

certificate. 
18. The operator may not permit any PIC to operate unless the PIC meets the operator’s qualification 

criteria and demonstrates the ability to safely operate the UAS in a manner consistent with how 

the UAS will be operated under the exemption, including evasive and emergency maneuvers and 

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

qualification flight hours must be logged in a manner consistent with 14 C.F.R. § 61.51(b). Flights 

for the purposes of training the operator’s PICs are permitted under the terms of the exemption. 

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

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

are considered nonparticipants, and the PIC must operate the UA with appropriate distance from 

nonparticipants in accordance with 14 C.F.R. § 91.119. 

19. UAS operations may not be conducted during night, as defined in 14 C.F.R. § 1.1. All operations 

must be conducted under visual meteorological conditions (VMC). If flight at night is required, a 

special request will be made at the FAA office closest to proposed area of operations. Flights 

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

20. The UA may not operate within 5 nautical miles of an airport reference point as denoted on a 

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

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

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

made available to the Administrator upon request. 

21. The UA may not be operated less than 500 feet below or less than 2,000 feet horizontally from a 

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

22. If the UA loses communications or loses its GPS signal, it must return to a pre- determined 

location within the planned operating area and land or be recovered in accordance with the 

operating documents. 

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

with the operating documents. 

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

conditions) there is enough power to fly at normal cruising speed to the intended landing point 

and land the UA with 25% battery power remaining. 
25. Before conducting operations, the radio frequency spectrum used for operation and control of the 

UA must comply with the Federal Communications Commission (FCC) or other appropriate 

government oversight agency requirements. 

26. The documents required fewer than 14 C.F.R. 91.9 and 91.203 must be available to the PIC at 

the Ground Control Station of the UAS any time the UAS is operating. These documents must be 

made available to the Administrator or any law enforcement official upon request. 

27. The UA must remain clear and yield the right of way to all manned aviation operations and 

activities at all times. 

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

1) Flight operations must be conducted at least 500 feet from all nonparticipating persons (persons other 

than the PIC, SO, operator trainees or essential persons), vessels, vehicles, and structures unless: 

a) Barriers or structures are present that sufficiently protect nonparticipating persons from the UA 

and/or debris in the event of an accident. The operator must ensure that nonparticipating persons 

remain under such protection. If a situation arises where nonparticipating persons leave such 

protection and are within 500 feet of the UA, flight operations must cease immediately and/or; 

b) The aircraft is operated near vessels, vehicles or structures where the owner/controller of such 

vessels, vehicles or structures has granted permission and the PIC has made a safety 

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

present an undue hazard, and; 

1) Operations nearer to the PIC, SO, operator trainees or essential persons do not present an 

undue hazard to those persons per § 91.119(a). 

29. All operations shall be conducted over private or controlled-access property with permission from 

the land owner/controller or authorized representative. Permission from land owner/controller or 

authorized representative will be obtained for each flight to be conducted. 

30. Any incident, accident, or flight operation that transgresses the lateral or vertical boundaries of 

the operational area as defined by the applicable COA must be reported to the FAA's UAS 

Integration Office (AFS-80) within 24 hours. Accidents must be reported to the National 

Transportation Safety Board (NTSB) per instructions contained on the NTSB Web site: 

www.ntsb.gov. 

2. Reasons Why An Exemption From The Requirements Of Section 61.113(a) And (b) Would Not 

Adversely Affect Safety. 
Discovery Drones, LLC. 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 1UAS unless that PIC 

has demonstrated, by meeting minimum flight-hour and currency requirements, that the PIC is able to 

safely operate the DJI Inspire 1 UAS in a manner consistent with the exemption, including evasive and 

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

structures. 

Considering Discovery Drones, LLC.’s proposed area of operations, and the operating limitations set 

forth-above; the parallel nature of private pilot aeronautical knowledge requirements to those of 

commercial pilot requirements (See Exemption No. 11062); and the airmanship skills necessary to safely 

operate the DJI Inspire 1UAS, Discovery Drones, LLC. submits that the additional manned airmanship 

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

Discovery Drones, LLC.’s specific proposed flight operations. 

The FAA has previously granted relief from Section 61.113(a) and (b) specific to UAS, in circumstances 

similar, in all material respects, to those presented herein (e.g. Exemption Nos. 11062, 11063, 11064, 

11065, 11066, 11067, 11080, 11109, 11110, 11112, 11136, 11138, 11150, 11153, 11156, 11158, 11159, 

11160, 11161). 

Discovery Drones, LLC. will not allow any PIC to operate the DJI Inspire 1UAS unless that PIC has 

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

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

with this exemption, including evasive and emergency maneuvers and maintaining appropriate distances 

from people, vessels, vehicles and structures. 

Specifically, the PIC must have accumulated and logged, in a manner consistent with 14 C.F.R. § 

61.51(b), 25 hours of total time as a UAS rotorcraft pilot (with a minimum of 5 hours of those hours as a 

UAS pilot operating the same make and model of UAS to be used for operations under the exemption). In 

addition to the hour requirements, the PIC must accomplish 3 takeoffs and landings in the preceding 90 

days (for currency purposes). 

As in Exemption Nos. 11062, 11138, and 11153, prior documented flight experience that was obtained in 

compliance with applicable regulations will ensure an equivalent level of safety during Discovery Drones, 

LLC.’s proposed operations. The Administrator has held that prior documented flight experience that was 

obtained in compliance with applicable regulations would ensure safe operations, stating as follows: 
In Exemption No. 11062, the FAA required that prior to conducting operations for the purpose of motion 

picture filming (or similar operations), the PIC must have accumulated and logged, in a manner consistent 

with 14 CFR 61.51(b), 25 hours of total time as a UAS rotorcraft pilot including at least 10 hours logged 

as a UAS pilot with a multi-rotor UAS. Prior to operations under Exemption No. 11062, the PIC must also 

have accumulated and logged a minimum of 5 hours as a UAS pilot operating the same make and model 

of UAS to be used for operations under the exemption. For clarification, the FAA considers these 

minimum hour requirements to be inclusive rather than additive; i.e. 5 hours make and model time may 

be included in the 10 hours of multi-rotor time and the 10 hours may be included in the total 25 hours of 

UAS rotorcraft time. In addition to the hour requirements, the PIC must accomplish 3 takeoffs and 

landings in the preceding 90 days (for currency purposes). The FAA finds that at a minimum, the flighthour requirements in Exemption No. 11062 are appropriate to practice and build proficiency in the skills 

necessary to safely conduct the petitioner’s proposed operations. The FAA also finds that prior 

documented flight experience that was obtained in compliance with applicable regulations would satisfy 

this requirement. Training, proficiency, and experience-building flights can also be conducted under the 

grant of exemption to accomplish the required flight time. During training, proficiency, and experiencebuilding flights the PIC is required to operate the UA with appropriate distances in accordance with 14 

C.F.R 91.119. 

Exemption No. 11138 at page 15. 

Accordingly, Discovery Drones, LLC. will ensure safe operations by not allowing any PIC to operate the 

DJI Inspire 1 UAS unless that PIC has demonstrated, by meeting minimum flight-hour and currency 

requirements, that the PIC is able to safely operate the DJI Inspire 1UAS in a manner consistent with the 

exemption, including evasive and emergency maneuvers and maintaining appropriate distances from 

people, vessels, vehicles and structures. 

3. Reasons Why An Exemption From The Requirements Of Section 91.7(a) Would Not Adversely Affect 

Safety. 

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

flight, Discovery Drones, LLC. will ensure that the DJI Inspire 1 UAS is in an airworthy condition based 

upon the UAS’s compliance with its operating documents and as stated in the conditions and limitations 

herein. 

Additionally, the FAA has previously granted relief from Section 91.7(a) specific to UAS, in circumstances 

similar, in all material respects, to those presented herein (e.g. Exemption Nos. 11062, 11063, 11064, 
11065, 11066, 11067, 11080, 11109, 11110, 11112, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 

11159, 11160, 11161). 

4. Reasons Why an Exemption From The Requirements Of Section 91.121 Would Not Adversely Affect 

Safety. 

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

information of the DJI Inspire 1 UAS will be provided to the PIC via GPS equipment and a radio 

communications telemetry data link, which downlinks from the UA to the GCS for active monitoring of the 

flight path and altitude. This altitude information, combined with Discovery Drones, LLC.’s operation of the 

DJI Inspire 1UAS within visual line of sight, at or below 500 feet AGL, will ensure a level of safety 

equivalent to Section 91.121. The altitude information will be generated by GPS equipment installed 

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

UAS at ground level. 

The FAA has previously granted relief from Section 91.121 specific to UAS, in circumstances similar, in all 

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

11067, 11080, 11109, 11112, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161). 

5. Reasons Why an Exemption From The Requirements Of Section 91.151(b) Would Not Adversely Affect 

Safety. 

A grant of this exemption would ensure an equivalent level of safety established by 14 C.F.R. Section 

91.151(b) as a result of (1) the technical specifications of the DJI Inspire 1UAS; (2) the limitations on the 

proposed flight operations; and (3) the location of the proposed flight operations. Accordingly, Discovery 

Drones, LLC. will ensure that it will safely operate the battery powered DJI Inspire 1 UAS during daylight 

hours in VFR conditions, with enough battery power to fly for a total duration of 23 minutes. 

Here, as in Exemption No. 11109, the technical specifications of the DJI Inspire 1UAS; the limitations on 

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

level of safety established by 14 C.F.R. Section 91.151(b). Furthermore, safety will be ensured as the DJI 

Inspire 1 UAS provide audible and visual warnings to the PIC at the GCS when the UAS experiences low 

battery voltage, the first warning occurring at approximately 30% remaining battery power, and again at 

approximately 10% remaining battery power. At the critically low battery level, the DJI Inspire 1UAS will 

descend and land automatically.
Significantly, previous exemptions granted by the FAA concerning Section 91.151 establish that safety is 

not adversely affected when the technical characteristics and operating limitations of the UAS are 

considered. Relief has been granted for manned aircraft to operate at less than the minimums prescribed 

in Section 91.151, including Exemption Nos. 2689, 5745, and 10650. Moreover, the FAA has previously 

granted relief from Section 91.151 specific to UAS, in circumstances similar, in all material respects, to 

those presented herein (e.g. Exemption Nos. 8811, 10808, 10673, 11042, 11062, 11063, 11064, 11065, 

11066, 11067, 11080, 11109, 11110, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 

11161). 

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

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

In seeking this exemption, Discovery Drones, LLC. submits that the equivalent level of safety with regard 

to the regulatory maintenance and alteration requirements established by Sections 91.405(a), 

91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) will be met because Discovery Drones, LLC. will 

use trained technicians to perform maintenance, alterations, or preventive maintenance on the UAS using 

the methods, techniques, and practices prescribed in the operating documents (i.e., DJI Inspire 1

Instruction Manual). Furthermore, Discovery Drones, LLC. will document and maintain all maintenance 

records for the DJI Inspire 1UAS. 

Since the DJI Inspire 1UAS will be inspected as prescribed by the operating documents, Discovery 

Drones, LLC. will maintain the equivalent level of safety established by Sections 91.405(a), 91.409(a)(1), 

and 91.409(a)(2). 

Likewise, the exemption sought will not adversely affect safety because Discovery Drones, LLC. will use 

trained technicians to perform maintenance, alterations or preventive maintenance on the UAS using the 

methods, techniques, and practices prescribed by the operating documents. 

Furthermore, the exemption sought would maintain an equivalent level of safety established by Sections 

91.407, 91.417(a) and 91.417(b), because all maintenance of the DJI Inspire 1 UAS will be performed by 

trained technicians. Maintenance will be documented and maintained utilizing the monthly maintenance 

log. 

Significantly, previous exemptions granted by the FAA concerning Sections 91.405(a), 91.407(a)(1), 

91.409(a)(1) & (a)(2), and 91.417(a) & (b) establish that safety is not adversely affected when the 

technical characteristics and operating limitations of the UAS are considered. 
In consideration of Discovery Drones, LLC.’s proposed operating limitations, the operating documents, 

and the technical aspects of the DJI Inspire 1UAS, Discovery Drones, LLC. submits that safety will not be 

adversely affected by granting exemption from 14 C.F.R. Sections 91.405(a), 91.407(a)(1) and (a)(2), 

91.409(a)(2), and 91.417(a) and (b). The FAA has previously granted relief specific to UAS in 

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

11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112, 11136, 11138, 11150, 11153, 11156, 

11157, 11158, 11159, 11160, 11161). 

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

In accordance with Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA) and 14 C.F.R. 

§ 21.16 entitled Special Conditions, Discovery Drones, LLC. requests that the FAA prescribe special 

conditions for the intended operation of the DJI Inspire 1UAS, 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, 91.151(b), 91.405(a), 

91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b). Such special conditions will permit safe 

operation of the UAS for the limited purpose of conducting aerial video and photography over certain 

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

considering whether a UAS will create a hazard to users of the NAS or the public, or otherwise pose a 

threat to national security; and further, provides the authority for such UAS to operate without 

airworthiness certification in accordance with any requirements that must be established for the safe 

operation of the UAS in the NAS. 

Likewise, the Administrator may prescribe special conditions pursuant to 14 C.F.R. § 21.16, for operation 

of the DJI Inspire 1UAS, since the airworthiness regulations of 14 C.F.R. Part 21 do not contain adequate 

or appropriate safety standards, due to the novel or unusual design features of the aircraft. Section 21.16, 

entitled Special Conditions, states the following: 

If the FAA finds that the airworthiness regulations of this subchapter do not contain adequate or 

appropriate safety standards for an aircraft, aircraft engine, or propeller because of a novel or unusual 

design feature of the aircraft, aircraft engine or propeller, he prescribes special conditions and 

amendments thereto for the product. The special conditions are issued in accordance with Part 11 of this 

chapter and contain such safety standards for the aircraft, aircraft engine or propeller as the FAA finds 

necessary to establish a level of safety equivalent to that established in the regulations. 

See 14 C.F.R. § 21.16. 
Therefore, in accordance with FMRA Section 333 and 14 C.F.R. § 21.16, the FAA may prescribe special 

conditions for Leading Edge’s intended operation of the DJI Inspire 1UAS, 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, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) 

& (b). 

• A Summary That Can Be Published In The Federal Register, stating: The Rules From Which Discovery 

Drones, LLC. seeks Exemption: 

Discovery Drones, LLC. seeks exemption from the requirements of 14 C.F.R Sections 61.113(a)&(b), 

91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b). 

A Brief Description of the Nature Of The Exemption Discovery Drones, LLC. seeks: 

This exemption will permit Discovery Drones, LLC.to commercially operate an Unmanned Aircraft System 

(UAS) for the purpose of conducting aerial video and photography over certain areas of the United States. 

• Any Additional Information, Views, Or Arguments Available to Support Discovery Drones, LLC.’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, Discovery Drones, LLC.’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, Discovery Drones, LLC. 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, Discovery Drones, LLC. seeks an exemption pursuant to 14 C.F.R. § 11.61 and 

Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA), which will permit safe operation 

of the DJI Inspire 1UAS commercially, without an airworthiness certificate, for the limited purpose of 

conducting aerial video and photography over certain areas of the United States. By granting this Petition, 

the FAA Administrator will be fulfilling the Congressional mandate of the FAA Modernization and Reform 

Act of 2012, while also advancing the interests of the public, by allowing Discovery Drones, LLC.to safely, 

efficiently, and economically operate the DJI Inspire 1UAS commercially within the NAS. 

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

Reform Act of 2012, Section 333, Discovery Drones, LLC. respectfully requests that the Administrator 

grant this Petition for an exemption from the requirements of 14 C.F.R Sections 61.113(a) & (b), 91.7(a), 

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

Leading Edge to operate the DJI Inspire 1UAS commercially for the purpose of conducting aerial video 

and photography over certain areas of the United States. 

Douglass Chouinard CEO/ Discovery Drones, LLC.