1415	Marietta	Road

Lancaster,	Ohio		43130

Phone:	740.407.4542

E-mail:	clandis2015@outlook.com

October	22nd,	2015

U.S.	Department	of	Transportation

Docket	Management	System

1200	New	Jersey	Ave.,	SE

Washington,	DC,	20590

RE: Exemption	Request	Under	Section	333	of	the	FAA	Modernization	and	Reform	

Act	of 2012	and	14	C.F.R.	Part	11

Dear	Madam,	Sir,

Pursuant	to	Section	333	of	the	FAA	Modernization	and	Reform	Act	of	2012	and	14	C.F.R.	

Part	 11,	 Aero	 Drone	 Design	 &	 Logistics	 seeks	 an	 exemption	 from	 the	 Federal	 Aviation	

Regulations	detailed	below	for	the	DJI	Inspire	1	UAS.	The	UAS	has	a	maximum	gross	takeoff	

weight	 of	 1.30	 kilograms.	 The	 proposed	 UAS	 is	 multi-rotor	 aircraft	 utilizing	 lithium	

polymer	batteries	too	power	four	(4)	electric	motors,	each	motor	driving	one	propeller,	all	

of	 which	 provide	 propulsion.	 This	 UAS	 is	 a	 commercial	 platforms	 manufactured	 by	 DJI	

Inovations;	 an	 aero	 drone	 manufacturing	 company	 with	 a	 proven	 track	 record	 and	 has	

been	widely	accepted	by	a	large	number	of	commercial	drone	operators	under	numerous	

FAA	Certificates	of	Autorization	(COA).

The	requested	exemption	will	enable	Aero	Drone	Design	&	Logistics	to	conduct	commercial	

operations	 involving aerial	 data	 collection	 using	 a	 small	 unmanned	 aircraft	 system.	 The	

system	 indicated	 above will	 be	 used	 to	 conduct	 data	 acquisition for	 agricultural	

applications,	 aerial	 inspections,	 aerial	 mapping,	 aerial	 surveying,	 R&D	 for	 further	 drone	

development,	 R&D	 to	 further	 enhance	 safety	 and	 operational	 procedures,	 and	 future

product and	 service demonstrations.	 Aero	 Drone	 Design	 and	 Logistics will	 operate	 in	

accordance	with	FAA N	8900.227	and	utilize	both	a	pilot	in	command	(PIC)	 and	a	groundbased	visual	observer (VO).	Aero	Drone	Design	&	Logistics	 will	also	utilize	emergency,	lost	

link,	and	lost	communication	procedures	that	are	available	upon	request.	All	flights	under	

these	exemptions	will	be	conducted	with	the	following	restrictions:

1. All	UAS	flight	operations will	be	conducted	in	Class	G	airspace	at	altitudes	less	than	

400’	AGL.
2. All	UAS	flight	operations	will	be	conducted	over	private	property,	and only	with	the	

permission	of	the	property	owner.

3. No	flight	operations	will	be	conducted	over	populated	areas.

4. No	 flight	 operations	 will	 be	 conducted	 within	 5	NM	 of	 public	 civilian	 or	 military	

airports.

5. All	 flight	 operations	 will	 be	 conducted	 during	 daylight	 hours	 and	 in	 visual	

meteorological	conditions (VMC).

6. The	PIC	will	ensure	at	all	times	the	UAS	being	operated	remain	within	visual	line	of	

sight	of	the	PIC	or	the	VO	and	will	remain	within	1⁄2	nautical	mile	of	the	PIC.

7. A	NOTAM	will	be	issued	prior	to	any	flight	operation.

8. No	flight	operations	will	be	conducted	utilizing	a	UAS	with	a	maximum	gross	takeoff	weight	(GTOW)	of	more	than 55	lbs.

9. No	flight	operations	will	be	conducted	utilizing	a	UAS	unless	the	aircraft	displays	a	

proper U.S.	registration	number.

10. All	PICs and	VOs	will	possess	certifications	required	under	N	8900.227.

11. No	 operator	 or	 observer	will	 engage	 in,	 nor	may	 an	 operator	 or	 observer	permit,	

any	 activity	 during	 a	 critical	 phase	 of	 flight	 which	 could	 distract	 any	 operator	 or	

observer	from	the	performance	of	his/her	duties	or	interfere	in	any	way	with	the	

proper	conduct	of	his/her	duties.

12. The	PIC	will	 conduct	a	pre-flight	inspection	prior	to	each	flight in	order	to	ensure

the	UAS	intended	for	 current	operations	 and	the	UAS	 associated	 systems	 are	in	 a	

condition	which	will	permit	safe	operation.

13. During	all	flight	operations,	the	PIC	and	VO will	maintain	two-way	communications.

if	unable	to	maintain	two-way	communications,	or	if	any	condition	occurs	that	may	

otherwise	 cause	 the	 flight	 operation	 to	 be	 unsafe,	 the	 operator	 will	 immediately	

conclude	the	flight	operation.

14. The	 aircraft	 intended	 for	 use	 (see	 paragraph	 one)	 will have	 the	 capability	 to

automatically	return	to	a	specific	location	if	the	communications	link	is	lost	at	any	

time	during	flight	operations.

15. All	flight	operations	will	be	conducted	below	70mph	as	derived	UASs	onboard	GPS.
The	 regulations	 from	 which	 the	 exemption	 is	 requested	 are	 as	 follows (the	 Appendix	

contains	details of Aero	Drone	Design	&	Logistics operations	related	to	showing	an	equivalent	

level	of	safety	for	these	exempt	regulations).

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

14	C.F.R.	§91.203(a)	and	(b)

14	C.F.R.	§45.23(b)

14	C.F.R.	§61.23(a)

14	C.F.R.	§61.113(a)	and	(b)

14 C.F.R.	§61.133(a)

14	C.F.R.	§91.7(a)

14	C.F.R.	§91.9

14	C.F.R.	§91.109(a)

14	C.F.R.	§91.119

14	C.F.R.	§91.121

14	C.F.R.	§91.151(a)

14	C.F.R.	Subpart	E	(§91.401	- §91.417)

UAS	Overview

Aero	Drone	Design	&	Logistics is	submitting	this	request	for	the	DJI	Inspire	1	multi-rotor	

platform.	These	commercially	available	systems	from	DJI	have demonstrated	reliability,	as	

well	as popularity	among	hobbyists	and	professionals.	Aero	Drone	Design	&	Logistics	has	

expertise	 and	 knowledge	 in	the	 operation	 of	this	 system.	Aero	Drone	Design	&	Logistics	

will	adhere	to	training	and	operational procedures	that	follow	the	guidelines	presented	in	

N	8900.227	and	the	guidelines	and	safety	recommendations	as	published	by	DJI.

Aero	Drone	Design	&	Logistics	intends	on	utilizing	the	DJI	Inspire	1	UAS to	pursue	further	

commercial	 applications. The	 DJI	 Inspire	 1	 UAS is	 a	 multi-rotor	 aircraft	 which	 utilizes

electric	 propulsion supplied	 by	 lithium	 polymer	 batteries.	 Figure	 1	 below	 contains	 an	

image	of	the	DJI	Inspire	1	UAS.	 Experts	proposes	that	the small	size	and	weight	of	the	UAS	

included	in	this	request	for	exemption,	flown	under	the	guidelines	of	N 8900.227,	will	have	

an	equivalent	level	of	safety	to	manned	aircraft	performing	similar	missions.

Figure 1
Aircraft	Dimensions	Weight (DJI	INSPIRE	1)

Dimensions: 17”	x	18”	x	12”

Weight: 6.5	Lbs.

The	name	and	contact	information	of	the	applicant	are:

Aero	Drone	Design	&	Logistics,	LLC

Attn:	Christopher	A.	Landis

Phone:	740.407.4542

E-mail:	clandis2015@outlook.com

Aero	 Drone	 Design	 &	 Logistics requests	 exemption	 under	 Section	 333	 for	 the	

purpose	of	providing safe, commercial	UAS	flight	operations	for	the activities	stated.	

By	approving	these	exemptions	the	FAA	will	create	benefits	to	the	areas	mentioned	

that	are,	ultimately, in	the	public	interest.	Please	contact	us	if	you	require	additional	

information	or	clarification.

Sincerely,

Christopher	A.	Landis

President

Aero	Drone	Design	&	Logistics,	LLC
APPENDIX

Specific Exemption Requests and Equivalent Level of Safety Showings

14 C.F.R. Part 21, Subpart H: Airworthiness Certificates

14 C.F.R. §91.203(a) and (b) - Civil aircraft: Certifications required.

Section 91.203 requires all civil aircraft to have a certificate of airworthiness. Part 21, Subpart H, entitled

Airworthiness Certificates, establishes the procedural requirements for the issuance of airworthiness 

certificates as required by FAR §91.203(a). Aero Drone Design & Logistics requests an exemption from 

these rules and will utilize an internal airworthiness process based on the following DJI manuals:

 Inspire 1 User Manual

 Inspire 1 Safety Guidelines

 Inspire 1 Intelligent Flight Batter Safety Guidelines

 1345s Quick-Release Propeller for the Inspire 1

 Inspire 1 Maintenance Manual

Such an exemption meets the requirements of an equivalent level of safety under Part 11 and Section

333 of the Reform Act. The Federal Aviation Act and Section 333 of the Reform Act both authorize the

FAA to exempt aircraft from the requirement for an airworthiness certificate, upon consideration of the 

size, weight, speed, operational capability, and proximity to airports and populated areas of the UAS 

involved.

14 C.F.R. §45.23(b) - Display of marks; general.

These regulations provide that each aircraft must display "N" and the aircraft’s registration number in

letters at least 3 inches high. Additionally, the aircraft must display the word "EXPERIMENTAL" in letters 

at least 2 inches high near the entrance to the cabin, cockpit, or pilot station. Given the size of the UAS 

(fuselage length of 17”’), this requirement is impossible to match. The equivalent level of safety will be

achieved by having the registered N-number in 1 inch lettering on the side of the fuselage.

14 C.F.R. §61.23(a) - Medical certificates: Requirement and duration.

Regulations provide that a person must hold at least a second class medical certificate when exercising:

 Second-in-command privileges of an airline transport pilot certificate in part 121 of this chapter 

(other than operations specified in paragraph (a)(1)(ii) of this section); or

 Privileges of a commercial pilot certificate

Given the size of the UAS in this petition and the limited flight area and the safety features integrated in

the autopilot, Aero Drone Design & Logistics believes that an equivalent level of safety can be maintained

if the operator has a valid driver’s license.

14 C.F.R. §61.113(a) and (b), §61.133 - Private Pilot Privileges and Limitations: Pilot in Command; 

Commercial Pilot Privileges and Limitations

Subsections (a) and (b) of §61.113 prohibit private pilots from operating aircraft in commercial operations,

and §61.133(a) requires an individual operating an aircraft for compensation or hire to hold a commercial

pilot certificate.

Aero Drone Design & Logistics requests an exemption from 14 C.F.R. §61.113(a) and (b) and 14 C.F.R. 

§61.133(a) so that UAS specified in this exemption may be operated by individuals who have a private 

pilot certificate. Based upon the design features of the UAS, its autopilot system, and safety factors, the 
FAA should permit operation of the UAS by operators with a private pilot certificate when the conditions 

described above have been satisfied. The above-described conditions are in-line with those set forth in 

Volume 16, Chapter 4, Section 1 of FAA Order 8900.1.

Aero Drone Design & Logistics proposes to conduct operations in accordance with these restrictions. 

Given these conditions and restrictions, an equivalent level of safety to manned flight operations will be 

maintained by drone operators who possess a private pilot certificate. The risks associated with the 

operation of the DJI Inspire1 multi-rotor aircraft (considering the size, speed, operational capabilities, and 

lack of combustible fuel) are considerably less than the level of risk associated with manned fixed wing 

and rotorcraft operations, both private and commercial, as contemplated by Part 61. Therefore, 

permitting operation of DJI Inspire 1 UAS, as set forth above, meets or exceeds the present level of 

safety provided under 14 C.F.R. §61.113(a) and (b) and §61.133(a).

14 C.F.R. §91.7(a) - Civil aircraft flight manual, marking, and placard requirements

This regulation requires that no person may operate a civil aircraft unless it is in airworthy condition. Aero 

Drone Design & Logistics requests that an exemption be granted permitting commercial operation without 

an airworthiness certificate. Given the size of the aircraft, self-certification utilizing the following DJI 

manuals will provide an equivalent level of safety:

 Inspire 1 User Manual

 Inspire 1 Safety Guidelines

 Inspire 1 Intelligent Flight Batter Safety Guidelines

 1345s Quick-Release Propeller for the Inspire 1

 Inspire 1 Maintenance Manual

14 C.F.R. §91.9(b)- Civil aircraft flight manual, marking, and placard requirements.

This regulation provides that no person may operate an aircraft unless a current, approved flight manual 

is located in the aircraft. Aero Drone Design & Logistics assumes that the intent of this requirement is to 

ensure that aircraft safety of flight an operational information located in the flight manual is available to 

the aircrew while operating the aircraft. 

Aero Drone Design & Logistics requests an exemption to this requirement since the aircraft is unmanned 

of a size in which placing aircraft manuals on board the UAS during flight is not practical, and 

documented operating and safety of flight information would not be available to the crew. The equivalent 

level of safety will be achieved by keeping a hard copy of the following DJI manuals with the PIC on the 

ground during flight operations:

 Inspire 1 User Manual

 Inspire 1 Safety Guidelines

 Inspire 1 Intelligent Flight Batter Safety Guidelines

 1345s Quick-Release Propeller for the Inspire 1

 Inspire 1 Maintenance Manual

14 C.F.R. §91.109(a) - Flight instruction; Simulated instrument flight and certain flight tests

Sections 91.109(a) provides that no person may operate a civil aircraft that is being used for flight 

instruction unless that aircraft has fully functioning dual controls. The UAS indicated in this exemption are 

remotely piloted aircraft, and, by design, not equipped with fully functional dual controls. Flight control is 

accomplished through the use of a control box that communicates with the aircraft via radio 

communications. Utilizing a pilot skilled in remote control piloting will provide an equivalent level of safety. 

14 C.F.R. §91.119 - Minimum safe altitudes: General.

The regulation provides that over sparsely populated areas the aircraft cannot be operated closer than 

500
feet to any person, vessel, vehicle, or structure. Since the UAS indicated in this exemption will be 

operating at a maximum of 400 feet AGL, the requirements of this regulation cannot be adhered to. In 

order to provide an equivalent level of safety Aero Drone Design & Logistics will only fly over private 

property with the permission of the land owner. The land owner will be briefed on the intended route of 

flight and the associated risks to persons and property on the ground. Aero Drone Design & Logistics

maintains that, due to the small size of the DJI Inspire 1 UAS, the hazard to persons and property is not 

comparable to manned aircraft, and should be considered in granting the exemption. Furthermore, Aero 

Drone Design & Logistics will not operate over congested areas, nor over any open air assembly of 

persons.

14 C.F.R. §91.121 - Altimeter settings.

The regulation states that aircraft shall maintain cruising altitudes by reference to an altimeter setting

available within 100 nautical miles of the aircraft. The UAS will fly below 400 feet AGL and will not need to

maintain hemispherical cruising altitudes in order to maintain required altitude separation with other 

aircraft. In order to maintain an equivalent level of safety, the DJI Inspire 1 autopilot calculates the 

reference altitude (the UAS altitude while positioned on the ground) and compares that altitude with the 

altitude determined by the on-board GPS during the pre-flight tests. The GPS and barometer data are 

then used to calculate the altitude in-flight.

14 C.F.R. §91.151(a) - Fuel requirements for flight in VFR conditions.

The regulation states that no person may begin a flight in an airplane under day-VFR conditions unless

there is enough fuel to fly to the first point of intended landing and to fly after that for at least 30 minutes. 

The DJI Inspire 1 UAS utilizes a lithium polymer battery to provide power to the propulsion system. 

Therefore, since the UAS does not carry fuel on board, the requirements in this regulation are not 

applicable. 

An equivalent level of safety is achieved through a low battery power warning. The PIC has the ability to 

select the percentage of battery power remaining in which this warning is displayed. The DJI Inspire 1 

UAS are designed to automatically return to base and land safely when the battery power becomes low, 

but before the battery power becomes low enough to become a safety of flight issue.

14 C.F.R. Subpart E (§91.401 - §91.417) - Maintenance, Preventive Maintenance, and Alterations

The regulation provides that the operator is primarily responsible for maintaining the aircraft in an 

airworthy condition, including compliance with part 39 and 43. Paragraphs 91.407 and 91.409 require 

that the aircraft be "approved for return to service by a person authorized under 43.7" after maintenance 

and inspection due to the small size and simplicity of the DJI Inspire 1, it is the intent of Aero Drone 

Design & Logistics to authorize the PIC to perform maintenance and inspection of the aircraft and 

approve the aircraft for return to service. 

The PIC will ensure that the aircraft is in an airworthy condition prior to flight and conduct detailed 

inspections after every 10 flight hours. Additionally, checklists will be utilized with all of the necessary

pre-flight procedures prior to every flight operation. The PIC will document work performed in accordance 

with 91.417. Due to the small size, construction, and simplicity of the aircraft, Aero Drone Design & 

Logistics believes the PIC is able to ensure an equivalent level of safety.