1



## 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@ vantagep ointap .com2 

## 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 E3

A. Petition Summary
Pursuant with Section 333 of the FAA Modernization and Reform Act of 2012, Vantage Point Aerial Photography, Inc. (Vantage Point) request s exemption from the following Federal Aviation Re gulations that are found under Title 14 of the Code of Federal Regulations (C FR) : 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 an d 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 documen t 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 o f military UAS experience. Vantage Point ’s aviation
and UAS background make it an ideal candidate t o t ackle the unique challenges associate d w it h comm ercial 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 lightwei ght battery

- operated quadcopter , ground control station, and associated data link equipment. The DJI I nspire 1 weighs only 6 .5 lbs. with overall4

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 I nspire 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 mainte nance and inspection procedures

.5

C. Statutory Authority 1. FAA Modernization and Reform Act of 2012, Sec tion 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 rul ema king 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 i nto 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
Sec tion 333 (b), S ec tion 333 (c) then gives the FAA the authority to decide if an airworthiness certification as specified by Title 49 U nited States Code , S ection 44704 is even required for operation . Section 333 (c) specifically states that the FAA can determine “w hether a certificate of waiver, certificate of authorization, or airworthiness certification under section 44704 of T itle 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 Sec tion 333 (b) to operate within the NAS without an airworthiness certification as long as the UAS does not pose any hazar d or threat to the NAS, public, and national security. 2. H ow 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 ea ch of these criteria.6

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 , t hus making it

an exponentially safer al ternative to manned aircraft s or helicopters for aerial data collection

. b. Operational Capability The primary function of the DJI Inspire 1 is to provide aerial data collect ion using a camera that is ca pable 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 aircraft s or helicopters and thus greatly benefit s the economy and the p ublic. The DJI Inspire 1 doesn’ t require an airport or heliport for take

- off or land ing but rather utilizes VTOL on

- site . Once airborne , the DJI Inspire 1 will 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 ens ure 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

sa fer alternative for aerial data collection and would pose a minimal ha zard to the NAS or public.7

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 (V MC) during day

light hours. The DJI Inspire 1 will operate within 1 NM and VLOS of the Pilot ( and the Safety Obs erver positioned next to the Pilo t ) at an altitude 400 ft

. AGL or less

. Th e 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.8

3. Other Relevant Factors

a. Operational Limitations
Vanta ge Point has established the following operational limitations for DJI Inspire 1 flights and will be bound by these limi tations 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 f

lights 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 a ircraft remains within VLOS

.

o The DJI Inspire 1 will operate in accordance with Day V isual Fl ight
R ules and only in V isual M eteorological C onditions during daylight hours

.9

o The d uration o f 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

- off

s 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 non

participating persons, vessels and vehicles unless the owner/c ontroller 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 c ancelled in th e 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,10

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 accomplishe d 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 t o conducting further operations

.

o The Pilot wil l file a NOTAM for DJI Inspire 1 f light s at each s ite, providing at a minimum , radial/DM E , 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 seek s exemption, with specifics on the e xtent of relief sought, reason for relief, and why exemption would not adversely affect safety.

a. Part 21 Subpart H

– Airworthiness Certificatio n Part 21 Subpart H establishes the requirements for the issuance of an airwor thiness certificate

. Vantage Point seeks com plete exemption from Part 21 Subpart H pursuant with Section 333 , which authorizes the FAA to exempt a UAS from the requirements o f an airworthiness certificate base d on consideration of11 the following: size, weigh, speed, operation al capability, proximi ty to airports and populated areas , and operation within VLOS

. An equal level of safety will be achieved with the o perational l imitations established in this document ( Reference C .3.a) for all DJI Inspire 1 f lights. Specifically that all flights will occur within VLOS of the Pilot and Safety Observe r , 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

o perating limitations will result in a safer alternative for aerial data collection.
b. 61.113 (a) (b): Priv ate Pilot Privileges and Limitations

– Pilot in Command 61.113 (a) l imits private pilots to non - commercial flights operations and
61.113 (b) provides an exemption that allows a private pilot to as act as pilo t 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
t hat the flight be incidental to the business.
As laid o ut in Vantage Point’s operational limitations (Reference Section
C. 3.a) the Pilot operating the DJI Inspire 1 will have an airline transport,12 commercial, recreation, or sport pilot certificate and have completed a UAS flight training course

. An equal if not grea ter 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

- in

safety 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 pro perty on the ground.

c. 91.9 (b)

– Civil A ircraft F light M anual in the A ircraft 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 a ircraft f light

m anual onboard. In addition to this the DJI Inspire 1 is unmanned and the Pilot is located at the g round c ontrol s tation. Vantage Point thus seeks exemption from the requirement to carry the a ircraf t f light m anual o nboa rd. Vantage Point instead
proposes that the DJI Inspire Operating Documents ( Appendix A

- E ) which contain information normally foun d in an aircraft flight manual, be kept at the
g round c ontrol s tation where it is readily assessable to t he Pilot and Safety Observer for reference. If it were physically possible for these required documents to be place d onboard the aircraft , the Pilot and Safety Observer would have no means of accessing the information due to the fac t that DJI Inspire 1 is unmanned with no aircrew onboard. Therefore an equal level of safety will be meet by keeping the13 DJI Inspire 1 Operating Documents at the g round c ontrol s tation 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 A ction 91.103 requires that the Pilot be familiar with specific information before each flight such as weather , forecast, and fuel requirements. In addition to t his the Pilot must be familiar with information found within the approved f light m anual relating to aircraft performance and take

- off and landing distances. Due to the fact that the DJI Inspire 1 has no FAA

- approved f light m anual , Vantage Point seeks
exemp tion 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 f light

m anual. T hese publications ha ve extensive pre - flight checklist s 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 c omparable to the information found in a FAA

- approved f light m anual, 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 91.103.14

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

comm unicates with the aircraft via line of s ight (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
p assenge rs on board. In addition the DJI Inspire 1 ’s small size and weight is significantly less hazard ous 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 ha ving two sets of controls. f. 91.119

– Minimum Safe Altitude 91.119 establishes the minimum altitude that civil air craft 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 prescribe d 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 flight15

characteristics to a helicopter should fall under the minimum safe attitude
reg ulations outlined in 91.119 (d) . H owever an exemption from this sect ion 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 l i mitations 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 P ilot 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 flight s over private or control access property with owners ’ consent. In addition the DJI Inspire 1 ’s small size and
f rame are significantly less hazard ous to persons and property on t he 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 de

conf liction with manned aircraft. For these reason s Vantage Point seeks exemption from this regulation. An equal level of safety will be achieved through the DJI Inspire 1 ’s GPS, which provide s altitude and location data to the Pilot via the ground control16

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 t he DJI Inspire 1 will not create a hazard to any manned aircraft maintaining hemispheric crui sing 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 fligh t 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 full y charged battery. Compliance with the regulation woul d 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

r each 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 anywh ere over the private or controlled access property. An equal level of safety will be ma intained 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 assoc iated 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.17

i. Part 91 Subpart E (91.401
- 91.417)

– Maintenance, Preventative Mai ntenance, 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 ai rcraft other than as prescribed in this subpart and other applicable regulations, in cluding
P art 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 c ertificate 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 provide s step

- by

- step instructions on Regular Maintenance, Preventive Maintenance , and Co rrective Maintenance . The Pilot will be responsible for conducting maintenance in accordance with the se procedures . Any DJI Inspire 1 maintenance that is not covered in these procedures will be performed by the manufacture r . Vantage Point will ensure that all maintenance perfo rmed on the DJI Inspire 1 by the P ilot and manufacture r is documented in accordance with 91.407 (a) (1). Specificall y that the records will include “a description of the work perf ormed; and the date of completion of t he work performed; and the signature...of the person approving
the aircraft for return to service”. T he P ilot will authorize the DJI Inspire 1 for return to service for all maintenance covered in the DJI Inspire 1 Maintenance Manual , and the manufacture r wil l authorize the DJI Inspire 1 for return to service for all maintenance that is outside the scope of the DJI Inspire 1 Maintenance18

Manual

. Vantage Point will also ensure that no modifications or alterations are made to the airframe that affect the flight o perating characteristics of the DJI Inspire 1

. 3. How request benefits public as a whole The DJI Inspire 1 is a safe, efficient, and an e conomical alternative to manned aircraft s and helicopters that are currently being used to conduct aeri al data collection

. There are a three major reasons why the p ublic would benefit from granting Vantage Point exem ptions from these regulations. Authorizing DJI Inspire 1 flights would 1) reduce the number of manned aircraft s and helicopters in the NAS, 2) reduce a ir and noise pollution, and 3) reduce the risk to l ife and property on the ground. Util izing 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 fe wer 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 P ilot , 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 th e public. At 6.5 lbs

. the battery operated DJI Inspire 1 wit h four small electric motors provides a much quieter alternative to manned aircraft s 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 motor s will be ex ponentially quieter than a twin

- engine19

combustion motor on passenger aircraft or a singl e engine three bladed light utility helicopter . In addition the DJI Inspire 1 requires no fuel since it is battery operated. A

mann ed aircraft or helicopter on the other hand typically burn s 20

- 30 gallons of aviation fuel per hour which is polluting the ai r not only over location but also over the path of transit and around the airport. Con ducting 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 collate ral damage. In addition the DJI Inspire 1 is unmanned and as a result t he risk associated with piloting this aircraft is non

existent. 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 Vanta ge Point Pre

- Flight Checklist (Appendix E)20

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 In spire 1 Unmanned Aerial System for the purpose of providing aerial data collection.