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Vantage Point Aerial Photography, Inc.’s Petition for Exemption for 

DJI Inspire 1 Unmanned Aerial System 

FAA Rules Docket: ___________

Submitted on 08 Nov 2015

Tim Ray, CEO

Vantage Point Aerial Photography, Inc

2529 N. Lincoln Ave Suite E2

Loveland, CO 80538

Phone: 970-443-5475

Email: tim@vantagepointap.com
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Table of Contents

Petition Summary....................................................................................................3

Background .............................................................................................................3

Statutory Authority .................................................................................................5

Basis for Petition.....................................................................................................10

DJI Inspire 1 Quick Start Guide..............................................................Appendix A

DJI Inspire 1 User Manual......................................................................Appendix B

DJI Inspire 1 Maintenance Manual.........................................................Appendix C

DJI Inspire 1 Safety Guidelines..............................................................Appendix D

Vantage Point Pre-Flight Checklist ........................................................Appendix E
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A. Petition Summary

Pursuant with Section 333 of the FAA Modernization and Reform Act of 2012, Vantage 

Point Aerial Photography, Inc. (Vantage Point) requests exemption from the following Federal 

Aviation Regulations that are found under Title 14 of the Code of Federal Regulations (CFR): 

Part 21 Subpart H, 61.113 (a) (b), 91.9 (b), 91.103, 91.109, 91.119, 91.121, 91.151 (a), Part 91 

Subpart E (91.401-91.417). Vantage Point seeks expedited approval and exemption from the

CFRs listed above in order to operate the DJI Inspire 1 Unmanned Aircraft System (UAS) for the 

purpose of providing aerial data. Operation of the DJI Inspire 1 by Vantage Point will follow 

strict operational limitations as outlined in this document or as may be established by the FAA 

upon grant of approval.

B. Background 

1. Vantage Point, Inc

Vantage Point is a photography company located in Loveland, CO that provides

aerial photography and ground-based elevated photography for the real estate, 

architectural, agricultural, and marketing industries. Vantage Point’s founder and CEO 

has 10 years of experience in the aviation industry as a civilian and military pilot and has 

three years and 1000 plus hours of military UAS experience. Vantage Point’s aviation 

and UAS background make it an ideal candidate to tackle the unique challenges 

associated with commercial UAS operations in the National Airspace System (NAS). 

2. DJI Inspire 1

The DJI Inspire 1 UAS is manufactured by the Chinese technology company DJI. 

The UAS includes a lightweight battery-operated quadcopter, ground control station, and 

associated data link equipment. The DJI Inspire 1 weighs only 6.5 lbs. with overall 
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dimensions of 1.4 ft. by 1.5 ft. by 0.9 ft. The DJI Inspire 1 is powered by a lithium 

polymer battery that drives four brushless motors attached to 13 in carbon fiber rotors. It 

has retractable landing gear, uses vertical takeoff and landing (VTOL), and has a 

maximum flight time of 18 minutes. The DJI Inspire has an ascent speed of 11 mph, a 

descent speed of 9 mph, and a maximum operating speed of 49 mph. The quadcopter is 

linked to the ground control station via a 2.4 GHz modem with a maximum data link 

range of 1.1 NM. If the DJI Inspire loses link with the ground control station or detects a 

low battery state at any time, it will initiate a return-to-home (RTH) procedure. 

For additional information on the DJI Inspire 1, reference Appendix A (DJI 

Inspire 1 Quick Start Guide), Appendix B (DJI Inspire 1 User Manual), Appendix C (DJI 

Inspire Maintenance Manual), and Appendix D (DJI Inspire 1 Safety Guidelines) which 

specify manufacturing information, aircraft performance, operating limits, normal and 

emergency procedures, fail-safe features, and maintenance and inspection procedures.
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C. Statutory Authority

1. FAA Modernization and Reform Act of 2012, Section 333

Section 333 (a) states that the FAA “shall determine if certain unmanned aircraft 

systems may operate safety in the national airspace system before completion of the plan 

and rulemaking required by Section 332”. Section 333 (b) then lists several factors that 

should be considered in determining which UAS’ would be eligible for expedited 

integration into the NAS. Specifically UAS’ that “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 the users of the national airspace system or 

the public, or pose a threat to national security”. If a UAS meets the criteria laid forth in 

Section 333 (b), Section 333 (c) then gives the FAA the authority to decide if an 

airworthiness certification as specified by Title 49 United States Code, Section 44704 is 

even required for operation. Section 333 (c) specifically states that the FAA can 

determine “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”. Thus, the FAA has the ability to allow a UAS 

that meets the criteria put forth in Section 333 (b) to operate within the NAS without an 

airworthiness certification as long as the UAS does not pose any hazard or threat to the 

NAS, public, and national security.

2. How Vantage Point meets the criteria laid forth in Section 333

Below are the criteria laid forth in Section 333 (b) and a detailed description of 

how Vantage Point meets each of these criteria. 
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a. Size, Weight, and Speed

The DJI Inspire 1 is small in size at just under two feet in diameter and 

one foot in height. It weighs only 6.5 lbs. and has a maximum operating speed of 

49 mph. This small, lightweight quadcopter that operates at relatively slow speeds 

will poses little-to-no hazard to people or structures on the ground, thus making it 

an exponentially safer alternative to manned aircrafts or helicopters for aerial data 

collection. 

b. Operational Capability

The primary function of the DJI Inspire 1 is to provide aerial data 

collection using a camera that is capable of shooting 4k video or taking 12 

megapixel photos. Utilizing a small UAS for aerial data collection is more cost 

effective and a safer option than large manned aircrafts or helicopters and thus 

greatly benefits the economy and the public.

The DJI Inspire 1 doesn’t require an airport or heliport for take-off or 

landing but rather utilizes VTOL on-site. Once airborne, the DJI Inspire 1will 

operate at an altitude of 400 ft. AGL or less and either fly over an area or hover 

over a fixed point collecting data. Prior to flight the Pilot will define the flight 

area and flight parameters to ensure safe operation of the DJI Inspire 1. If onboard 

sensors detect a critical issue at any time, such as lost link condition or low 

battery state, a RTH procedure will be initiated (Reference Appendix B). The DJI 

Inspire 1’s small operational footprint and built-in safety protocol provide a much 

safer alternative for aerial data collection and would pose a minimal hazard to the 

NAS or public. 
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c. Proximity to Airports/Populated Areas

The DJI Inspire 1 will only operate over private property or controlled 

access property, and prior to flight operations Vantage Point will obtain 

permission from the property owner or controller. In addition the DJI Inspire 1 

will remain at least 500 ft. from all non-participating persons, vessels, and 

vehicles unless the owner/controller has granted permission and operating closer 

doesn’t present a hazard. Vantage Point will also ensure that flight operations are 

not within 5 NM of an airport unless a letter of agreement with airport

management has been obtained. The DJI Inspire 1 will also operate at an altitude 

of 400 ft. AGL or less, and as a result will be laterally de-conflicted from manned 

aircraft operations. By operating at low altitudes over private or controlled access 

property the DJI Inspire 1 will pose no threat to individuals or structures on the 

ground and will remain well clear of any and all air traffic. 

d. Visual Line of Sight (VLOS)

The DJI Inspire 1 will be flown in accordance with day Visual Flight 

Rules (VFR) and only in Visual Meteorological Conditions (VMC) during daylight hours. The DJI Inspire 1 will operate within 1 NM and VLOS of the Pilot 

(and the Safety Observer positioned next to the Pilot) at an altitude 400 ft. AGL or 

less. The Safety Observer will be responsible for ensuring that the DJI Inspire 1

remains within VLOS at all times and will also assist in spotting potential 

hazards. 
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3. Other Relevant Factors 

a. Operational Limitations

Vantage Point has established the following operational limitations for DJI 

Inspire 1 flights and will be bound by these limitations and/or any conditions and

limitations established by the FAA in accordance with Sec 333 (c) which states 

that after determining if a UAS meets the criteria the FAA “shall [also] establish 

requirements for the safe operation of the” UAS in the NAS.

o DJI Inspire 1 flights will only occur over private property or controlled 

access property and prior to flight operations permission from the 

property owner or controller will be obtained.

o The DJI Inspire 1 will operate at or below 400 ft. AGL.

o The DJI Inspire 1 will not exceed a 49 mph (approx. 40 knots)

operating speed.

o The DJI Inspire 1 will operate within 1 NM and within VLOS of the 

Pilot and Safety Observer

o The Safety Observer will be located next to the Pilot and assist in 

spotting any potential hazards as well as ensuring that the aircraft 

remains within VLOS.

o The DJI Inspire 1 will operate in accordance with Day Visual Flight 

Rules and only in Visual Meteorological Conditions during daylight 

hours.
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o The duration of each DJI Inspire 1 flight shall not exceed 14 minutes, 

ensuring that 4 minutes or approximately 20% of the battery life 

remains for landing.

o All take-offs and landings will occur on-site in accordance with the 

SenseFly DJI Inspire 1 User Manual (Reference Appendix B).

o The Pilot will conduct a pre-flight inspection (Reference Appendix E)

prior to commencing flight operations to ensure that the DJI Inspire 1

is in a condition safe for flight.

o DJI Inspire 1 flights will remain at least 500 ft. from all nonparticipating persons, vessels and vehicles unless the owner/controller 

has granted permission and operating closer doesn’t present a hazard.

o DJI Inspire 1 flight operations will not occur within 5 NM of an airport 

unless a letter of agreement with airport management has been 

obtained.

o DJI Inspire 1 flight operations will be conducted by a Pilot who holds 

an airline transport, commercial, recreation, or sport pilot certificate 

and a FAA airman medical certificate or valid U.S. driver’s license.

o The Pilot will complete a UAS flight training course prior to 

commencing DJI Inspire 1 flight operations for Vantage Point.

o DJI Inspire 1 flights will be cancelled in the event that any aircraft or 

ground control station equipment is inoperative or not fully functional.

o If the Pilot or Safety Observer spot a potential hazard, such as a 

manned aircraft within close proximity to the designated flight area, 
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the Pilot will immediately land the DJI Inspire 1 and operations will 

only resume after the hazard is clear of the area.

o All DJI Inspire 1 maintenance will be accomplished in accordance 

with the DJI Inspire 1 Maintenance Manual (Reference Appendix C)

o If the DJI Inspire 1 undergoes any maintenance or alteration that 

affects the flight characteristics of the UAS, a functional flight test will 

be performed prior to conducting further operations.

o The Pilot will file a NOTAM for DJI Inspire 1 flights at each site, 

providing at a minimum, radial/DME, radius, and a date/time group

D. Basis for Petition

1. Name and Address of the Petitioner

Vantage Point Aerial Photography, Inc.

2529 N. Lincoln Ave Suite E2

Loveland, CO 80538

Phone: 970-443-5475

Email: tim@vantagepointap.com

2. Specific Sections of 14 CFR from which Vantage Point Seeks Exemption

Below are the sections from which Vantage Point seeks exemption, with specifics

on the extent of relief sought, reason for relief, and why exemption would not adversely 

affect safety.

a. Part 21 Subpart H – Airworthiness Certification

Part 21 Subpart H establishes the requirements for the issuance of an 

airworthiness certificate. Vantage Point seeks complete exemption from Part 21 

Subpart H pursuant with Section 333, which authorizes the FAA to exempt a UAS 

from the requirements of an airworthiness certificate based on consideration of 
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the following: size, weigh, speed, operational capability, proximity to airports and 

populated areas, and operation within VLOS. 

An equal level of safety will be achieved with the operational limitations 

established in this document (Reference C.3.a) for all DJI Inspire 1 flights. 

Specifically that all flights will occur within VLOS of the Pilot and Safety 

Observer, at an altitude of 400 ft. AGL or less, and over private or controlled 

access property. As a result the DJI Inspire 1 can safely operate without creating a 

hazard to any other manned aircraft and people or structures on the ground. The 

DJI Inspire 1’s small, lightweight frame in conjunction with Vantage Point’s

operating limitations will result in a safer alternative for aerial data collection.

b. 61.113 (a) (b): Private Pilot Privileges and Limitations – Pilot in 

Command

61.113 (a) limits private pilots to non-commercial flights operations and 

61.113 (b) provides an exemption that allows a private pilot to as act as pilot in 

command of the aircraft if “the flight is only incidental to the business or 

property” and “the aircraft does not carry passengers or property for 

compensation or hire”. The DJI Inspire 1 due to its size is not capable of carrying 

passengers or property but the flight would not be incidental, but rather essential 

to Vantage Point. Vantage Point seeks exemption to section (a) that prevents 

private pilots from commercial flight operations and/or section (b) which requires 

that the flight be incidental to the business.

As laid out in Vantage Point’s operational limitations (Reference Section

C.3.a) the Pilot operating the DJI Inspire 1 will have an airline transport, 
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commercial, recreation, or sport pilot certificate and have completed a UAS flight 

training course. An equal if not greater level of safety is achieved by the fact that 

the DJI Inspire 1 is remotely controlled with no living thing onboard, unlike a 

conventional manned aircraft or helicopter that carries the pilot, passengers, and 

combustible material. The DJI Inspire 1 also has a robust autopilot and built-insafety features which greatly reduce the risk of human error. The area of operation 

will also be controlled and all flights will be coordinated in advance thus greatly 

diminishing all risks to the NAS and persons or property on the ground.

c. 91.9 (b) – Civil Aircraft Flight Manual in the Aircraft

91.9 (b) states that no person may operate an aircraft unless there is a 

current approved flight manual for the aircraft onboard. The DJI Inspire 1’s small 

and lightweight frame is not physically capable of carrying an aircraft flight 

manual onboard. In addition to this the DJI Inspire 1 is unmanned and the Pilot is 

located at the ground control station. Vantage Point thus seeks exemption from 

the requirement to carry the aircraft flight manual onboard. Vantage Point instead 

proposes that the DJI Inspire Operating Documents (Appendix A-E) which 

contain information normally found in an aircraft flight manual, be kept at the

ground control station where it is readily assessable to the Pilot and Safety 

Observer for reference. 

If it were physically possible for these required documents to be placed

onboard the aircraft, the Pilot and Safety Observer would have no means of 

accessing the information due to the fact that DJI Inspire 1 is unmanned with no 

aircrew onboard. Therefore an equal level of safety will be meet by keeping the 
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DJI Inspire 1 Operating Documents at the ground control station where it will be 

readily accessible (within arm’s reach) to the Pilot who is operating the aircraft, 

thus meeting the intent of the regulation. 

d. 91.103 – Preflight Action

91.103 requires that the Pilot be familiar with specific information before 

each flight such as weather, forecast, and fuel requirements. In addition to this the 

Pilot must be familiar with information found within the approved flight manual 

relating to aircraft performance and take-off and landing distances. Due to the fact 

that the DJI Inspire 1 has no FAA-approved flight manual, Vantage Point seeks 

exemption from this regulation. Vantage Point proposes to use the DJI Inspire 1

User Manual, DJI Inspire 1 Safety Guidelines, and Vantage Point Pre-Flight 

Checklist (Reference Appendix A, D, and E) in lieu of an FAA-approved flight 

manual. These publications have extensive pre-flight checklists that include

reviewing weather, battery requirements, take-off and landing distances, and 

aircraft performance data.

The information found in the DJI Inspire 1 User Manual, DJI Inspire 1 

Safety Guidelines, and Vantage Point Pre-Flight Checklist is comparable to the 

information found in a FAA-approved flight manual, to include a comprehensive 

step-by-step pre-flight checklist. As a result an equal level of safety will be 

maintained by the Pilot using these publications, which addresses the items listed 

in 91.103. 
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e. 91.109 – Flight Instruction

91.109 states that “no person may operate a civil aircraft that is being used 

for flight instruction unless that aircraft has fully functioning dual controls”. The 

DJI Inspire 1 is operated by the Pilot through a ground control station that 

communicates with the aircraft via line of sight (LOS) transmissions. The DJI 

Inspire 1 by design does not have fully functioning dual controls and as a result 

Vantage Point seeks exemption from this regulation. 

Exemption from this regulation requiring dual controls will not create a 

safety hazard, because the DJI Inspire 1 is unmanned and does not carry a pilot or 

passengers on board. In addition the DJI Inspire 1’s small size and weight is 

significantly less hazardous to persons and structures on the ground than a 

manned, fixed-wing aircraft or helicopter. Because the DJI Inspire 1 ground 

control station is remote-control based, it will be accessible to both the Instructor 

and Student at all times. The “controls” can in essence be passed back and forth 

between the Instructor and Student, achieving an equivalent level of safety as

having two sets of controls.

f. 91.119 – Minimum Safe Altitude

91.119 establishes the minimum altitude that civil aircraft may safely

operate at. 91.119 (d) states that helicopters may operate below the prescribed 

minimums if the “person operating the helicopter complies with any routes or 

altitudes specifically prescribed for helicopters by the FAA” and “operations 

(are) conducted without hazard to persons or property on the surface”. 

Vantage Point petitions that the DJI Inspire 1 quadcopter with similar flight 
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characteristics to a helicopter should fall under the minimum safe attitude 

regulations outlined in 91.119 (d). However an exemption from this section 

may still be required if there is a discrepancy in the categorization of the DJI 

Inspire 1 as a helicopter.

Vantage Point has established operating limitations to achieve an 

equivalent if not a higher level or safety, specifically that the DJI Inspire 1 will 

not operate above 400 ft. AGL and that the DJI Inspire 1 will remain within 

VLOS of the Pilot and Safety Observer. Furthermore Vantage Point will also 

ensure that the flight operations never pose a threat or hazard to persons or 

property on the ground by only conducting flights over private or control access 

property with owners’ consent. In addition the DJI Inspire 1’s small size and 

frame are significantly less hazardous to persons and property on the ground than 

a manned aircraft or helicopter providing the same service. 

g. 91.121 – Altimeter Settings

91.121 requires aircraft to maintain a cruising level or flight level in 

reference to a current reported altimeter setting. The DJI Inspire 1 is not equipped 

with a programmable altimeter but rather determines location and altitude via an 

onboard GPS. Also since the DJI Inspire 1 will be operating at or below 400 ft. 

AGL, there is no need to maintain hemispherical cruising altitudes for deconfliction with manned aircraft. For these reasons Vantage Point seeks 

exemption from this regulation. 

An equal level of safety will be achieved through the DJI Inspire 1’s GPS, 

which provides altitude and location data to the Pilot via the ground control 
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station. In addition the DJI Inspire 1’s altitude will be visually monitored by the 

Pilot and Safety Observer thus ensuring an equal level of safety is attained in lieu 

of referencing an altimeter setting. Furthermore by operating at or below 400 ft.

AGL the DJI Inspire 1 will not create a hazard to any manned aircraft maintaining 

hemispheric cruising altitudes based on a current altimeter setting.

h. 91.151 (a) – Fuel Requirements for Flight in VFR Conditions

91.151 (a) states that no person may begin a flight in Day VFR conditions 

unless there is enough fuel to fly to the intended landing point and fly for 30 

minutes after that point is reached. The DJI Inspire 1 is battery operated and does 

not carry fuel. It has a maximum flight time of 18 minutes on a fully charged 

battery. Compliance with the regulation would not even allow the DJI Inspire 1 to 

take-off and conduct flight operations. Vantage Point seeks full exemption from 

this regulation due to the fact that the risk or danger associated with failing to 

reach a safe landing point with 30 minutes of extra “fuel” does not exist with the 

DJI Inspire 1. The DJI Inspire 1 does not have to return to a “landing point” but 

rather can be safely put down anywhere over the private or controlled access 

property. 

An equal level of safety will be maintained by landing the DJI Inspire 1 

with 4 minutes (20%) of battery life. Furthermore the DJI Inspire 1 is designed to 

safely land anywhere in the event that the battery is exhausted past the 4 minute 

point. Any risk associated with battery duration (fuel) in relationship to flight time 

is mitigated by the fact that DJI Inspire 1 has the ability to land anywhere at any 

given time in the event of an emergency.
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i. Part 91 Subpart E (91.401-91.417) – Maintenance, Preventative 

Maintenance, and Alterations

These regulations provided the maintenance, and inspections requirements 

in reference to Part 39 and Part 43. 91.405 (a) specifically states that “no person 

may perform maintenance, preventive maintenance, and alterations on an aircraft 

other than as prescribed in this subpart and other applicable regulations, including 

Part 43 of this chapter”. Vantage Point seeks full exemption from these 

regulations due to the fact that these sections apply to an aircraft with an 

airworthiness certificate which the DJI Inspire 1 does not have.

An equal level of safety will be achieved by using the DJI Inspire 1

Maintenance Manual (Reference Appendix C) which provides step-by-step 

instructions on Regular Maintenance, Preventive Maintenance, and Corrective 

Maintenance. The Pilot will be responsible for conducting maintenance in 

accordance with these procedures. Any DJI Inspire 1 maintenance that is not 

covered in these procedures will be performed by the manufacturer. Vantage 

Point will ensure that all maintenance performed on the DJI Inspire 1 by the Pilot 

and manufacturer is documented in accordance with 91.407 (a) (1). Specifically 

that the records will include “a description of the work performed; and the date of 

completion of the work performed; and the signature...of the person approving 

the aircraft for return to service”. The Pilot will authorize the DJI Inspire 1 for 

return to service for all maintenance covered in the DJI Inspire 1 Maintenance 

Manual, and the manufacturer will authorize the DJI Inspire 1 for return to service

for all maintenance that is outside the scope of the DJI Inspire 1 Maintenance 
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Manual. Vantage Point will also ensure that no modifications or alterations are 

made to the airframe that affect the flight operating characteristics of the DJI 

Inspire 1. 

3. How request benefits public as a whole

The DJI Inspire 1 is a safe, efficient, and an economical alternative to manned 

aircrafts and helicopters that are currently being used to conduct aerial data collection. 

There are a three major reasons why the public would benefit from granting Vantage 

Point exemptions from these regulations. Authorizing DJI Inspire 1 flights would 1) 

reduce the number of manned aircrafts and helicopters in the NAS, 2) reduce air and 

noise pollution, and 3) reduce the risk to life and property on the ground.

Utilizing the DJI Inspire 1 in lieu of a traditional manned aircraft or helicopter 

would result in the overall reduction of manned aircraft in the NAS. Thus there will be 

fewer aircraft that require control and coordination with Air Traffic Controllers (ATC). 

Because the DJI Inspire 1 can take-off and land on-site and operate at an altitude of 400 

ft. AGL (or less) within VLOS of the Pilot, there is no need for ATC to provide

coordination during ground, take-off, departure, transit, arrival, and landing phases of 

flight. As the skies over the United States get busier and busier, any small effort to 

lighten the load of the Air Traffic Controllers would be of great benefit to the public. 

At 6.5 lbs. the battery operated DJI Inspire 1 with four small electric motors 

provides a much quieter alternative to manned aircrafts or helicopters. Traditionally a 

manned aircraft would have to transit from the departure airport to the desired site and fly 

at low altitudes to achieve the desired data collection. The DJI Inspire 1 will require no 

transit time, and the electric motors will be exponentially quieter than a twin-engine 
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combustion motor on passenger aircraft or a single engine three bladed light utility 

helicopter. In addition the DJI Inspire 1 requires no fuel since it is battery operated. A 

manned aircraft or helicopter on the other hand typically burns 20-30 gallons of aviation 

fuel per hour which is polluting the air not only over location but also over the path of 

transit and around the airport. Conducting aerial data collection with the DJI Inspire 1 in 

lieu of a manned aircraft or helicopter would thus greatly reduce both air pollution and 

noise pollution which is of great benefit to the public. 

Using the DJI Inspire 1 would also greatly reduce if not completely eliminate the 

risk to life and property on the ground. The DJI Inspire 1’s incredibly small size, reduced 

weight, and small frame pose no hazard to people or structures on the ground as opposed 

to a manned twin engine passenger aircraft or single engine three bladed light utility 

helicopter, which has a much greater potential for collateral damage. In addition the DJI 

Inspire 1 is unmanned and as a result the risk associated with piloting this aircraft is nonexistent. Overall the DJI Inspire 1 provides a much safer alternative to manned aircraft 

operations for the purpose of aerial data collection.

4. Additional information, views, and arguments

The following documents have been included as Appendices to this Petition. 

o DJI Inspire 1 Quick Start Guide (Appendix A)

o DJI Inspire 1 User Manual (Appendix B)

o DJI Inspire 1 Maintenance Manual (Appendix C)

o DJI Inspire 1 Safety Guidelines (Appendix D)

o Vantage Point Pre-Flight Checklist (Appendix E)
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5. Summary for Federal Register

Pursuant with Section 333 of the FAA Modernization and Reform Act of 2012, 

Vantage Point, LLC requests exemption from the following Federal Aviation Regulations 

that are found under Title 14 of the Code of Federal Regulations: Part 21 Subpart H, 

61.113 (a) (b), 91.9 (b), 91.103, 91.109, 91.119, 91.121, 91.151 (a), Part 91 Subpart E 

(91.401-91.417). Exemption from these regulations would allow Vantage Point, Inc. to 

operate the DJI Inspire 1 Unmanned Aerial System for the purpose of providing aerial 

data collection.