June 16, 2015

Exemption No. 11821

Regulatory Docket No. FAA–2015–1115

Mr. S. Pierce Ledbetter, Jr.

LEDIC Management Group, LLC

2650 Thousand Oaks Boulevard

Suite 3100

Memphis, TN 38118

Dear Mr. Ledbetter:

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

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

including the date it ends.

By letter dated April 14, 2015, you petitioned the Federal Aviation Administration (FAA) on 

behalf of LEDIC Management Group, LLC (hereinafter petitioner or operator) for an 

exemption. The petitioner requested to operate an unmanned aircraft system (UAS) to 

conduct aerial real estate video and photography.

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

the regulations that the petitioner seeks an exemption.

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

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

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

Airworthiness Certification

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

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

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

operating area associated with the aircraft and its operation, the Secretary of Transportation 
2

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

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

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

requirements of part 36, is not necessary.

The Basis for Our Decision

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

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

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

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

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

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

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

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

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

by this exemption is in the public interest.

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

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

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

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

11213 also apply to the situation you present; and 

• A grant of exemption is in the public interest.

Our Decision

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

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

delegated to me by the Administrator, LEDIC Management Group, LLC is granted an 

exemption from 14 CFR §§ 61.23(a) and (c), 61.101(e)(4) and (5), 61.113(a), 61.315(a), 

91.7(a), 91.119(c), 91.121, 91.151(a)(1), 91.405(a), 91.407(a)(1), 91.409(a)(1) and (2), and 

91.417(a) and (b), to the extent necessary to allow the petitioner to operate a UAS to perform 

aerial data collection. This exemption is subject to the conditions and limitations listed 

below.

 

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

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

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

instruments aboard the UA.
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Conditions and Limitations

In this grant of exemption, LEDIC Management Group, LLC is hereafter referred to as 

the operator.

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

grounds for the immediate suspension or rescission of this exemption.

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

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

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

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

not permitted. 

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

exemption holder may use either groundspeed or calibrated airspeed to determine 

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

airspeeds greater than the maximum UA operating airspeed recommended by the 

aircraft manufacturer.

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

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

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

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

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

U.S. driver’s license.

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

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

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

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

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

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

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

required of the VO.

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

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

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

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

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

limitations in this exemption and the procedures outlined in the operating documents, 
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the conditions and limitations herein take precedence and must be followed. 

Otherwise, the operator must follow the procedures as outlined in its operating 

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

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

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

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

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

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

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

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

updates or revisions to the operating documents.

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

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

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

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

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

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

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

in a condition for safe operation.

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

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

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

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

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

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

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

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

aircraft components.

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

safety bulletins.

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

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

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

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

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

14 CFR § 61.56 in an aircraft in which the PIC is rated on his or her pilot certificate.
5

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

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

operated under this exemption, including evasive and emergency maneuvers and 

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

to the Administrator or any law enforcement official upon request.

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

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

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

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

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

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

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

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

power recommended by the manufacturer if greater.

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

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

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

operations that cannot be conducted under the terms of the attached COA.
6

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

number, registered in accordance with 14 CFR part 47, and have identification 

(N−Number) markings in accordance with 14 CFR part 45, Subpart C. Markings must 

be as large as practicable.

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

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

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

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

official upon request.

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

activities at all times. 

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

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

persons, vessels, vehicles, and structures unless:

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

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

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

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

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

of nonparticipating persons; and

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

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

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

present an undue hazard.

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

nonparticipating persons under this exemption.

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

permission from the property owner/controller or authorized representative. 

Permission from property owner/controller or authorized representative will be 

obtained for each flight to be conducted.

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

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

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

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

contained on the NTSB Web site: www.ntsb.gov.
7

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

television filming and production, the following additional conditions and limitations apply.

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

as documented in this grant of exemption.

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

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

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

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

must include at least the following:

a. Dates and times for all flights;

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

under this grant of exemption;

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

the UAS;

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

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

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

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

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

g. Signature of exemption holder or representative; and

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

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

essential to accomplish the operation.

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

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

exemption holder’s MPTOM.

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

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

parts 45, 47, 61, and 91.
8

This exemption terminates on June 30, 2017, unless sooner superseded or rescinded.

Sincerely,

/s/

John S. Duncan

Director, Flight Standards Service

Enclosures
UNITED STATES OF AMERICA 

DEPARTMENT OF TRANSPORTATION 

FEDERAL AVIATION ADMINISTRATION 

WASHINGTON, DC 

Regulatory Docket No. _____ _ 

IN THE MATTER OF THE PETITION FOR SECTION 333 

EXEMPTION OF LEDIC MANAGEMENT GROUP LLC 

FOR A CERTIFICATE OF WAIVER OR AUTHORIZATION (COA) FOR 

FLIGHTS AT OR BELOW 200 FEET 

Submitted on April14, 2015 

S. Pierce Ledbetter, Jr. 

LEDIC Management Group, LLC 

2650 Thousand Oaks Blvd, Suite 3100 

Memphis, TN 3 8118 

Tel (901) 435-7710 

Pierce.Ledbetter@ledic.com 

pierceledbetter@yahoo.com 
TABLE OF CONTENTS 

Page 

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

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

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

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

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

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

THE SPECIFIC SECTIONS OF 14 C.P.R. FROM WHICH LEDIC 

MANAGEMENT GROUP LLC SEEKS 

EXEMPTION ................................................................. 9 

THE EXTENT OF RELIEF LEDIC MANAGEMENT GROUP LLC SEEKS 

AND THE REASON LEDIC MANAGEMENT GROUP LLC SEEKS THE 

RELIEF ......................... l3 

THE REASONS WHY GRANTING LEDIC MANAGEMENT GROUP LLC'S 

REQUEST WOULD BE IN THE PUBLIC INTEREST 

......................................................... 18 

THE REASONS WHY GRANTING THE EXEMPTION WOULD NOT 

ADVERSELY AFFECT SAFETY .......................................................................... 19 

SUMMARY THAT CAN BE PUBLISHED IN THE FEDERAL REGISTER ...... 34 

ANY ADDITIONAL INFORMATION, VIEWS, OR ARGUMENTS 

AVAILABLE TO SUPPORT LEDIC MANAGEMENT GROUP LLC'S 

REQUEST ........ .34 

CONCLUSION .................................................................................................................... 35 

APPENDICES .. ... ........ .. ......... .... ......... .. ................................................. 37 

2 
AGL 

AOI 

ATC 

ATO 

AV 

CPR 

COA 

FAA 

FAR 

GCS 

GPS 

LOL 

NAS 

NOT AM 

PIC 

Section 333 

so 

SOP 

UA 

UAS 

VFR 

VLOS 

VMC 

VTOL 

GLOSSARY OF ABBREVIATIONS 

Above Ground Level 

Area of Interest 

Air Traffic Control 

Air Traffic Organization 

Aerial Vehicle 

Code of Federal Regulations 

Certificate of Authorization 

Federal Aviation Administration 

Federal Aviation Regulation 

Ground Control Station 

Global Positioning System 

Loss of Link 

National Airspace System 

Notice to Airman 

Pilot In Command 

FAA Modernization and Reform Act of2012 (FMRA) Section 333 

Safety Observer 

Standard Operating Procedures 

Unmanned Aircraft 

Unmanned Aircraft System 

Visual Flight Rules 

Visual Line of Site 

Visual Meteorological Conditions 

Vertical Takeoff and Landing 

3 
SUMMARY 

Pierce Ledbetter 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)(l), 91.409(a)(l) & (a)(2), 

and 91.417(a) & (b), to operate an Unmanned Aircraft System pursuant to Section 333 of 

the FAA Modernization and Reform Act of 2012 (FMRA). This exemption will permit 

LEDIC Management Group LLC to operate an Unmanned Aircraft System (UAS) for 

flights at or below 200 feet for the commercial purpose of conducting aerial real estate 

video and photography of apartment communities managed by LEDIC Management Group 

LLC, where Pierce Ledbetter is CEO. 

INTRODUCTION AND INTERESTS OF THE PETITIONER 

LEDIC Management Group LLC provides its clients with the highest quality 

property management, with innovative approaches to marketing and resident safety 

programs. Pierce Ledbetter was awarded "1N Best" in 2013 by the Governor of Tennessee for 

remarkable achievement in the management of affordable housing. LEDIC Management Group 

has designed innovative camera systems for resident safety. The objective of LEDIC 

Management Group LLC aerial real estate video and photography operations is to provide 

high quality imaging for a variety of commercial, public, and residential uses, specifically 

targeting: 

• Aerial real estate photography of apartment communities. 

• Increase public knowledge ofUAS and promote safe UAS operations. 

4 
BACKGROUND 

Unmanned Aircraft Systems: DJI Inspire 1 UAS 

LEDIC Management Group LLC seeks an exemption to operate DJI systems for 

compensation or hire within the NAS. The DJI Inspire 1 is a vertical takeoff and landing 

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

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

of approximately 2935 grams (6.4 pounds), while having a length of 18 inches width of 18 

inches, height of 12 inches, and a maximum speed of approximately 42 knots. The DJI 

Inspire 1 UA is equipped with four main rotors; driven by Lithium Polymer battery 

powered electric motors. 

The DJI Inspire 1 UA that will be operated by LEDIC Management Group 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, LEDIC Management Group LLC, pursuant to the provisions of the 

Federal Aviation Regulations (14 C.F .R. § 11.61) and the FAA Modernization and Reform 

Act of2012 (FMRA), Section 333, Special Rules for Certain Unmanned Aircraft Systems, 

hereby petitions the Administrator to commercially operate the DJI Inspire 1 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)(l) & 

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

5 
In consideration of the speed, weight, size, and limited operating area associated 

with the unmanned aircraft and its operation, LEDIC Management Group LLC 

operation of DJ 

Inspire 1 UAS meets the conditions ofFMRA Section 333 and therefore, will not require 

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

Accordingly, LEDIC Management Group LLC requests relief from 

Sections 91.405(a), 

91.407(a)(l), 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. 

LEDIC Management Group LLC submits that the requested relief is proper since an 

equivalent level of safety will be ensured. LEDIC Management Group LLC will use 

experienced personnel or technicians to perform maintenance, alterations, or preventive 

maintenance on the UASs using the methods, techniques, and practices prescribed in the 

operating documents (i.e., Monthly Maintenance Log, and DJI Inspire 1 Instruction 

Manual). Furthermore, LEDIC Management Group LLC will document and maintain all 

maintenance records for the DJI Inspire 1 UAS. 

Relief from certain requirements of Section 61 .113( a) and (b), entitled Private pilot 

privileges and limitations: Pilot in command, is requested by LEDIC Management Group 

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 1 UAS in a manner consistent with this exemption, including 

evasive and emergency maneuvers and maintaining appropriate distances from people, 

vessels, vehicles and structures. 

6 
LEDIC Management Group LLC seeks relief from Section 91.7(a), entitled Civil 

aircraft aitworthiness, because the DJI Inspire 1 UAS do not require an airworthiness 

certificate in accordance with 14 C.F.R. Part 21, Subpart H. As such, LEDIC Management 

Group LLC 

7 
submits that it will ensure that the DJI Inspire 1 UAS are in an airworthy condition, prior 

to every flight, by determining that the UASs are in compliance with the operating 

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

that the aircraft are in a condition for safe flight. LEDIC Management Group LLC also 

seeks an exemption from the requirements of Section 

91.121, entitled Altimeter Settings, as the DJI Inspire 1 U A 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 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 LEDIC Management 

Group LLC's operation of the DJI Inspire 1 UAS within visual line of sight, at or below 200 

feet AGL, will ensure a level of safety equivalentto Section 91.121. 

Additionally, LEDIC Management Group LLC seeks an exemption from the 

requirements of Section 91.151(b), entitled Fuel requirements for flight in VFR conditions. 

LEDIC Management Group LLC submits that safety will not be affected by operation of the 

DJI Inspire 1 UA 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 13.5 minutes to the first point of intended landing and, assuming normal 

cruising speed, to fly after that for at least 4.5 minutes. 

In accordance with 14 C.P.R.§ 11.81, LEDIC Management Group LLC 

provides the following information in support of its petition for exemption: 

8 
A. Name And Address Of The Petitioner. 

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

S. Pierce Ledbetter, Jr. 

LEDIC Management Group, LLC 

2650 Thousand Oaks Blvd, Suite 3100 

Memphis, TN 38118 

Tel (901) 435-7710 

Pierce.Ledbetter@ledic.com 

pierceledbetter@yahoo.com 

B. The Specific Sections Of 14 C.F.R. From Which LEDIC Management Group LLC 

Seeks Exemption. 

1. LEDIC Management Group 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. LEDIC Management Group 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. LEDIC Management Group LLC Exemption From The Requirements Of 

Section 

9 
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 1 00 nautical miles of the aircraft; 

(ii) If there is no station within the area prescribed in paragraph (a)(l)(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. LEDIC Management Group LLC 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. LEDIC Management Group LLC Exemption From The Requirement Of 

Section 

91.405(a). 

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

Each owner or operator of an aircraft-

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

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

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

10 
6. LEDIC Management Group LLC Exemption From The Requirements Of 

Section 91.407(a)(l) Section 91.407, entitled Operation after maintenance, 

preventive maintenance, rebuilding, or alteration, subsection (a)(l), states the 

following: 

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

maintenance, rebuilding, or alteration unless--

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

43.7 of this chapter[.] 

7. LEDIC Management Group LLC Seeks Exemption From The Requirements 

Of Sections 

91.409(a)(l) 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. LEDIC Management Group LLC 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 ofthe 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 re;x;ords must 

include--

11 
(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 LEDIC Management Group LLC Seeks And The Reason 

LEDIC Management Group LLC Seeks The Relief. 

12 
1. Extent OfReliefLEDIC Management Group LLC Seeks And The Reason 

LEDIC Management Group LLC Seeks Relief From Section 61.113(a) And (b). 

13 
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, LEDIC Management Group LLC submits that an 

equivalent level of safety will be maintained because no PIC will be allowed to operate the 

DTI Inspire 1 UAS UA unless that PIC has met certain flight-hour and currency 

requirements, demonstrating that the PIC is able to safely operate either the DJI Inspire 1 

UAS 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, LEDIC Management Group 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 

LEDIC Management Group LLC business; and (2) will not carry passengers or property 

for compensation or hire. 

2. Extent OfReliefLEDIC Management Group LLC Seeks And The Reason 

LEDIC Management Group LLC Seeks Relief From Section 91.7(a). 

14 
Relief from Section 91.7 (a) entitled Civil aircraft airworthiness, is requested to the 

extent required to allow LEDIC Management Group 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., the LEDIC Management Group LLC Aerial 

Operations Manual, Monthly Maintenance Log, and DJI Inspire 1 Instruction Manual). 

LEDIC Management Group LLC seeks the requested reliefbecause the DJI Inspire 

1 UAS do not require an airworthiness certificate in accordance with 14 C.P.R. Part 21, 

Subpart H. Therefore, LEDIC Management Group LLC will ensure that the DJI Inspire 1 

UAS are in airworthy condition based upon its compliance with the operating documents 

(i.e., Monthly Maintenance Log, and 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 LEDIC Management Group LLC Seeks And The Reason 

LEDIC Management Group 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), LEDIC Management Group LLC seeks 

the requestedreliefbecause the DJI Inspire 1 UA's altimeter maybe set on the ground to 

zero feet AGL, rather than the local barometric pressure or field altitude, before each flight. 

15 
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 1 UAs 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 LEDIC Management Group LLC Seeks And The LEDIC 

Management Group LLC Relief From Section 91.15l(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 1 UAs during daylight hours in visual meteorological conditions (VMC), under 

visual flight rules (VFR), for a total duration of 22 minutes to the first point of intended 

la.'lding and, assuming normal cruising speed, to fly after that for at least 4.5 minutes. 

LEDIC Management Group LLC seeks the requested relief because without an exemption 

from Section 91.151 (b), the flight time duration of the battery powered DJI Inspire 1 

UA will severely constrain the practicality of any aerial real estate video or still photo 

flight operations that LEDIC Management Group LLC proposes to conduct pursuant to this 

Petition. 

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

UAS, the DJI Inspire 1 operating documents, and LEDIC Management Group LLC's 

proposed operating limitations, ensure that LEDIC Management Group LLC will safely 

operate the battery powered 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 22 minutes to the first point of intended landing and, 

16 
assuming nonnal cruising speed, to fly after that for at least 4.5 minutes. 

5. Extent OfReliefLEDIC Management Group LLC Seeks And The Reason 

LEDIC Management Group LLC Seeks Relief From Sections 91.405(a), 

91.407(a)(l), 

91.409(a)(l) & (a)(2), And 91.417(a) & (b). 

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

only apply to aircraft with an airworthiness certificate, LEDIC Management Group 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 meets the 

conditions ofFMRA Section 333 for operation without an airworthiness certificate. 

Accordingly, LEDIC Management Group LLC will use trained technicians to perfonn 

maintenance, alterations, or preventive maintenance on the UASs using the methods, 

techniques, and practices prescribed in the UAS operating documents (i.e., the LEDIC 

Management Group LLC Aerial Operations Manual, Monthly Maintenance Log, and DJI 

Inspire 1 Instruction Manual). Furthennore, LEDIC Management Group LLC will 

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

D. The Reasons Why Granting LEDIC Management Group 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 LEDIC 

Management Group LLC to safely, efficiently, and economically perform aerial real estate 

video and photography of apartment communities, aiding CPTED (Crime Prevention 

Through Environmental Design) analyses and assisting residents in evaluation of 

community amenities. 

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

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

LEDIC Management Group LLC's proposed operation of the DJI Inspire 1 UAS will be 

17 
realized without implicating any privacy issues. 

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

The DJI Inspire 1 UA 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 1 UAS would reduce the amount of manned 

aircraft in the NAS, reduce noise and air pollution, as well as increase the safety oflife and 

property in the air and on the ground. 

Furthennore, 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 1 UA do not require an airport to takeoff or land. Likewise, a reduction of 

manned aircraft conducting aerial real estate 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 1 UAS. 

Conducting aerial real estate acquisitions with the DJI Inspire 1 UAS, instead of 

manned aircraft, will greatly benefit the public by drastically reducing the levels of air and 

noise pollution generated during traditional aerial real estate video and still photography 

flight operations. By using battery power and electric motors, the DJI Inspire 1 UAS 

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 real estate video and photography, while burning approximately 20-30 gallons 

per hour ofleaded aviation fuel. The DJI Inspire 1 UA, while reducing the carbon footprint 

of aerial real estate acquisitions, also eliminates noise pollution, as the UAs are propelled 

18 
by battery powered electric motors, rather than an internal combustion engine. 

By using the DJI Inspire 1 VAS to perform aerial real estate acquisitions, the 

substantial risk to life and property in the air and on the ground, which is usually 

associated with traditional manned aircraft flight operati~ns, 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 2 pounds 11 ounces and 

6 pounds 7.5 ounces respectively, at their maximum gross weights with lengths of 16 inches 

and 17.3 inches respectively, widths of 16 inches and 17.7 inches respectively, 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 

approximately42 feet, a length of34 feet, and a fuel capacity of 180 gallons). 

3. Performing Aerial real estate Video and Photography Operations 

With The DJI Inspire 1 UAS Will Benefit The Economy. 

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

alternative to using manned aircraft to conduct similar aerial real estate operations. As such, 

operation of the DJI Inspire 1 VAS will allow United States based companies, like LEDIC 

Management Group 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 1 UAS is one such 

technology that not only allows companies greater operational flexibility compared to 

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

traditional manned aircraft. 

19 
By operating the DJI Inspire 1 UAS, companies such as LEDIC Management 

Group 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 1 UAS, provides a stable workforce that increases consumer 

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

in research and development in order to remain competitive both in the United States and 

abroad. 

4. There Are No Privacy Issues. 

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

decades, LEDIC Management Group LLC proposed operation of the DJI Inspire 1 UAS 

will not implicate any privacy issues. Specifically, the DJI Inspire 1 UAS will be operated 

only in compliance with operating documents (i.e., the LEDIC Management Group LLC 

Aerial Operations Manual, Monthly Maintenance Log, and DJI Inspire 1 Instruction 

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 LEDIC Management Group LLC Seeks 

Exemption. 

1. Reasons Why The DJI Inspire 1 UA Meet The Conditions Of The 

FAA Modernization and Reform Act of2012 (FMRA) Section 333. 

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

with the unmanned aircraft and its operation, LEDIC Management Group LLC operation 

of the DJI Inspire 1 UAS meet the conditions ofFMRA Sect.ion 333, and will not require 

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

20 
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.--Notwithstandingany 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 Safo Operation.--lfthe 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, LEDIC Management Group LLC submits that the DJI 

Inspire 1 UAS can operate safely in the NAS pursuant to FMRA Section 333, as 

21 
demonstrated by: (a) the characteristics of the DJI Inspire 1 UAS; (b) the pilot 

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

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

Safe Characteristics. 

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

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

operational capability. 

i. Technical Specifications Of The DJI Inspire 1 UAS. 

The technical specifications of the DJI Inspire 1 UAS is set forth by the 

DJI Inspire 1 Specifications and Data Sheet, attached hereto as Exhibit A. 

ii. The DJI Inspire 1 UAS Autonomous Flight And Navigation 

Modes Enable The UAS To Remain Within A De'fmed 

Operational Area. 

The DJI Inspire 1 UAS may be operated in both manual and fully autonomous 

flight modes. A complete description of the flight and navigational modes of the DJI 

Inspire 1 UAS is provided at pages 25-35 of the DJI Inspire 1 User Manual, attached hereto 

as Exhibit B. 

iii. The DJI Inspire 1 UAS 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 1 UA will remain stationary, in 

flight, for 3 seconds or more. If, after 3 seconds, the DJI Inspire 1 UA does not reacquire 

control link data from the GCS, the UA will assume that the Control Link is lost and the 

UA will return to the home position (i.e., failsafe mode) via GPS, and will descend to the 

takeoff position and shutdown. 

22 
A complete description of the Failsafe Functions of the DJI Inspire 1 UAS are 

set forth at pages 27 through 29 of the DJI Inspire 1 User Manual, attached hereto as B. 

iv. The DJI Inspire 1 GCS And Its Operation. 

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

GCS and flight control software is provided at pages 32 through 43 of the DJI Inspire 1 

User Manual. DJI Inspire 1 User Manual is attached hereto as Exhibit B. 

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

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

LEDIC Management Group LLC will only utilize certificated pilots who possess a 

current and valid airman medical certificate to act as a pilot in command (PIC) of the DJI 

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

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

Specific Operating Limitations in accordance with Section 333 

In seeking this exemption, proposes to commercially operate DJI Inspire 1 UAS for 

the special purpose of conducting aerial real estate 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 UASs weighing less than 

55 pounds maximum gross weight: DJI Inspire 1 Unmanned Aircraft System. 

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 real estate video and photography. 

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

23 
4. The UA must be operated at an altitude of no more than 200 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. All operations must 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 

VAS 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 

24 
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 U ASs 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 

25 
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 NOT AM 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 U A may not be operated less than 200 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 predetermined 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 

remmmng. 

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

of Waiver or Authorization (COA) prior to conducting any operations under the 

grant of exemption. This COA will also require the operator to request a Notice 

to Airman (NOT AM) not more than 72 hours in advance, but not less than 48 

hours prior to the operation. All operations shall be conducted in accordance 

with airspace requirements in the ATO issued COA including class of airspace, 

altitude level and potential transponder requirements. 

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

serial number, registered in accordance with 14 C.P.R. part 47, and have 

identification (N- Number) markings in accordance with 14 C.P.R. part 45, 

Subpart C. Markings must be as large as practicable. 

27. 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. 

28. The documents required fewer than 14 C.P.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. 

26 
29. The UA must remain clear and yield the right of way to all manned aviation 

operations and activities at all times. 

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

31. 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; 

c. Operations nearer to the PIC, SO, operator trainees or essential persons 

do not present an undue hazard to those persons per § 91.119( a). 

32. 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. 

33. 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. 

LEDIC Management Group 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 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 

27 
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 LEDIC Management Group LLC 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 ainnanship skills necessary to safely operate the DJI Inspire I UAS, 

LEDIC Management Group LLC submits that the additional manned airmanship 

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

necessary for LEDIC Management Group LLC 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). 

LEDIC Management Group LLC will not allow any PIC to operate the DJI Inspire 

I U AS unless that PIC has demonstrated, by meeting minimum flight-hour requirements or 

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

operate the DJI Inspire 1 UAS in a manner consistent with this exemption, including 

evasive and emergency maneuvers and maintaining appropriate distances from people, 

vessels, vehicles and structures. 

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 

28 
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 LEDIC Management Group LLC 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 61.5l(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 total25 hours ofUAS 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 flight-hour 

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 

experience-building flights the PIC is required to operate the UA with appropriate 

distances in accordance with 14 C.F .R 

91.119. Exemption No. 11138 at page 15. 

Accordingly, LEDIC Management Group LLC will ensure safe operations by not 

allowing any PIC to operate the DJI Inspire 1 UAS unless that PIC has demonstrated, by 

29 
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. 

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, LEDIC Management Group 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 UA 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 LEDIC Management Group LLC's operation of the DJI 

Inspire 1 UA within visual line of sight, at or below 200 feet AGL, will ensure a level of 

30 
safety equivalent to Section 91.121. The altitude information will be generated by GPS 

equipment installed on board the aircraft. Prior to each flight, a zero altitude initiation 

point is automatically established by the UASs 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 

91.15l(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 1 UAs; (2) the limitations on the proposed flight operations; and (3) the location 

of the proposed flight operations. Accordingly, LEDIC Management Group LLC will 

ensure that it will safely operate the battery powered DJI Inspire 1 UA during daylight 

hours in VFR conditions, with enough battery power to fly for a total duration of 13 .5 

minutes to the first point of intended landing and, assuming normal cruising speed, to fly 

after that for at least 4.5 minutes. 

Here, as in Exemption No. 11109, the technical specifications of the DJI Inspire 1 

UAS; the limitations on the proposed flight operations; and the location of the proposed 

operations, will ensure an equivalent level of safety established by 14 C.F .R. Section 

91 .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 33% remaining battery power, and again at 

approximately 10% remaining battery power. At the critically low battery level, the DJI 

31 
Inspire 1 UAS 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, 1113 8, 11150, 11153, 

11156, 

11157, 11158, 11159, 11160, 

11161). 

6. Reasons Why An Exemption From The Requirements Of Sections 

91.405(a), 91.407(a)(l), 91.409(a)(l) & (a)(2), And 91.417(a) & (b) Would 

Not Adversely Affect Safety. 

In seeking this exemption, LEDIC Management Group 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)(l), 91.409(a)(1) & (a)(2), and 

91.417(a) & (b) will be met because LEDIC Management Group 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., 

the LEDIC Management Group LLC Aerial Operations Manual, Monthly Maintenance 

Log, and DJI Inspire 1 Instruction Manual). Furthermore, LEDIC Management Group 

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

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

32 
documents, LEDIC Management Group LLC will maintain the equivalent level of 

safety established by Sections 91.405(a), 91.409(a)(l), and 91.409(a)(2). A copy of 

the DJI Inspire 1 User Manuals are attached hereto as Exhibit B; a copy of the DJI 

Inspire 1 UAS Maintenance LOG is attached hereto as Exhibit C. 

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

Management Group 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)(l), 91.409(a)(l) & (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 LEDIC Management Group LLC proposed operating 

limitations, the operating documents, and the technical aspects of the DJI Inspire 1 

UAS, LEDIC Management Group LLC submits that safety will not be adversely 

affected by granting exemption from 14 C.F.R. Sections 91.405(a), 91.407(a)(l) 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, 

33 
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 

Oper ation. 

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

2012 (FMRA) and 14 C.P.R. § 21.16 entitled Special Conditions, LEDIC Management 

Group LLC requests that the FAA prescribe special conditions for the 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 §§ 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 real estate 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 U AS will create a hazard to users of the NAS or the public, or otherwise pose a 

threat to national security; and further, provides the authority for such UAS to operate 

without airworthiness certification in accordance with any requirements that must be 

established for the safe operation of the UAS in the NAS. 

Likewise, the Administrator may prescribe special conditions pursuant to 14 C.F.R. 

§ 21.16, for operation of the DJI Inspire 1 UAS, since the airworthiness 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 cio 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 

34 
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.P.R.§ 21.16. 

Therefore, in accordance with FMRA Section 333 and 14 C.F .R. § 21 .16, the 

FAA may prescribe special conditions for LEDIC'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, 91.151(b), 91.405(a), 

91.407(a)(l), 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 LEDIC Management Group LLC Seeks Exemption: 

LEDIC Management Group LLC seeks exemption from the requirements of 14 

C.F.R Sections 

61.1 13(a)&(b), 91. 7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(J) 

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

A Brief Description Of The Nature Of The Exemption LEDIC 

Management Group LLC Seeks: 

This exemption will permit LEDIC Management Group LLC to commercially 

operate an Unmanned Aircraft System (UAS) for the purpose of conducting 

aerial real estate video and photography over certain areas of the United 

States, with particular focus on apartment communities. 

G. Any Additional Information, Views, Or Arguments Available To Support LEDIC 

Management Group LLC 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, LEDIC Management Group LLC 

request for exemption may be granted pursuant to the authority ofFMRA Section 333 

35 
and 14 C.P.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 N AS 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, LEDIC Management Group LLC will operate the DJI 

Inspire 1 UASs 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, LEDIC Management Group LLC seeks an exemption pursuant 

to 14 C.P.R. 

§ 11.61 and Section 333 of the FAA Modernization and Reform Act of2012 (FMRA), 

which will permit safe operation of the DJI Inspire 1 UAS commercially, without an 

airworthiness certificate, for the limited purpose of conducting aerial real estate video and 

photography over certain areas ofthe United States. By granting this Petition, the FAA 

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

Reform Act of2012, while also advancing the interests of the public, by allowing LEDIC 

Management Group LLC to safely, efficiently, and economically operate the DJI Inspire 1 

UAS commercially within the NAS. 

WHEREFORE, in accordance with the Federal Aviation Regulations and the 

FAA Modernization and Reform Act of2012, Section 333, LEDIC Management Group 

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, 91.15l(b), 

91.405(a), 91.407(a)(l), 

91.409(a)(l) & (a)(2), and 91.417(a) & (b), and permit LEDIC to operate the DJI 

Inspire 1 UAS commercially for the purpose of conducting aerial real estate video and 

36 
photography over certain areas of the United States 

Dated: April14, 2015 

Respectfully submitted, S. Pierce Ledbetter, Jr. 

37 

LEDIC Management Group LLC 

2650 Thousand Oaks Blvd, Suite 

3100 

Memphis TN 38118 

Tel (901) 435-7710 

Pierce.ledbetter@ledic. com