UNITED STATES OF AMERICA 

DEPARTMENT OF TRANSPORTATION 

FEDERAL AVIATION ADMINISTRATION WASHINGTON, DC

Regulatory Docket No. __________________

IN THE MATTER OF THE PETITION FOR EXEMPTION OF: Jeffrey Brock FOR AN EXEMPTION SEEKING RELIEF FROM THE 

REQUIREMENTS OF TITLE 14 OF THE CODE OF FEDERAL REGULATIONS SECTIONS 61.101(e)(4) & (5), 61.23(a), 61.315(a), 

91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), AND 91.417(a) & (b) CONCERNING 

COMMERCIAL OPERATION OF DJI INSPIRE 1 AND DJI PHANTOM 2 UNMANNED AIRCRAFT SYSTEMS PURSUANT TO 

SECTION 333 OF THE FAA MODERNIZATION AND REFORM ACT OF 2012 (PUBLIC LAW 112-95)

Submitted on 19 October 2015

Jeffrey Brock | 206 Oconee Dr | Cohutta, Georgia 30710 | 706-264-1568

Email: jeff@webmizer.com

TABLE OF CONTENTS

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

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

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

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

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

NAME AND ADDRESS OF PETITIONER. ................................................................................................................. 7

THE SPECIFIC SECTIONS OF 14 C.F.R. FROM WHICH JEFFREY BROCK SEEKS EXEMPTION............................ 8

THE EXTENT OF RELIEF Jeffrey Brock SEEKS AND THE REASON JEFFREY BROCK SEEKS THE RELIEF........... . 11

THE REASONS WHY GRANTING JEFFREY BROCK’S REQUEST WOULD BE IN THE PUBLIC INTEREST ............ 15

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 JEFFREY BROCK’S REQUEST.... 

.............................................................................................................................................................................. 34

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

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

2

GLOSSARY OF ABBREVIATIONS

 AGL Above Ground Level 

 AOI Area of Interest 

 ATC Air Traffic Control 

 ATO Air Traffic Organization 

 AV Aerial Vehicle 

 CFR Code of Federal Regulations 

 COA Certificate of Authorization

 FAA Federal Aviation Administration 
 FAR Federal Aviation Regulation 

 GCS Ground Control Station 

 GPS Global Positioning System 

 LOL Loss of Link 

 NAS National Airspace System 

 NOTAM Notice to Airman 

 PIC Pilot In Command 

 Section 333 FAA Modernization and Reform Act of 2012 (FMRA) Section 333 

 SO Safety Observer 

 SOP Standard Operating Procedures 

 UA Unmanned Aircraft 

 UAS Unmanned Aircraft System 

 VFR Visual Flight Rules 

 VLOS Visual Line of Site 

 VMC Visual Meteorological Conditions 

 VTOL Vertical Takeoff and Landing

3

SUMMARY

Jeffrey Brock seeks exemption from the requirements of 14 C.F.R §§ 61.101(e)(4) and (5), 61.315(a), 61.23(a), 91.7(a), 

91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b), to operate an Unmanned Aircraft

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

Jeffrey Brock to operate an Unmanned Aircraft System (UAS) for the commercial purpose of conducting aerial video and

photography of construction sites, building inspections, agricultural lands, outdoor recreational facilities, real estate, 

special events, and landscapes within the United States.

INTRODUCTION AND INTERESTS OF THE PETITIONER

Jeffrey Brock will provide its clients with high quality digital content for use in their commercial, personal, and non-profit 

multimedia projects. Jeffrey Brock has years of film making and photography experience and will use state-of-the-art 

technology to make high quality video and photo productions for any client. Jeffrey Brock has over 3 years 

recreational/hobby experience in all aspects of aerial video and photography. The objective of Jeffrey Brock aerial video 

and photography operations is to provide high quality imaging for a variety of commercial, public, and residential uses, 

specifically targeting:

 Aerial event filming and photography 

 Promotional videos for businesses, non-profits & government entities 

 Photo and video production for real estate marketing

4

BACKGROUND

Unmanned Aircraft Systems: DJI Inspire 1 UAS & DJI Phantom 2

Jeffrey Brock seeks an exemption to operate DJI systems for compensation or hire within the NAS. The DJI Inspire 1 

(Inspire 1) and DJI Phantom 2 are vertical takeoff and landing (VTOL) Unmanned Aircraft (UA) with a Ground Control 

Station (GCS) utilizing electronic tablet or smart phone systems. The Inspire 1 and Phantom 2 are electric powered 

rotary wing UAS that is capable of transmitting live airborne video images and location information to a Ground Control 
Station (GCS). Both the Phantom and Inspire store the photographs and data on board and makes them available for 

download after completion of the flight. The Inspire is 22 in x 22 in x 8 in and weighs 6.4 pounds, and the Phantom 2 is 

lighter at 2.2 pounds. 14 in x 14 in x 6 in. Both are well under the 55 lbs mandated in the FMRA. The Inspire has a 

maximum cruising speed of 42 knots while the Phantom has a maximum cruising speed of 29 knots. Both are battery 

powered, have a flight endurance of 22 minutes and can operate in temperatures ranging from 0° to 40° C. Both the 

Inspire and the Phantom 2 have omni-directional antenna with a range of 2.1 km and operating in the 2.420 – 2.483 GHz 

frequency range.

The Inspire 1 and Phantom 2 that will be operated by Jeffrey Brock 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.

5

BASIS FOR PETITION

The petitioner, Jeffrey Brock, pursuant to the provisions of the Federal Aviation Regulations (14 C.F.R. § 11.61) and the 

FAA Modernization and Reform Act of 2012 (FMRA), Section 333, Special Rules for Certain Unmanned Aircraft Systems, 

hereby petitions the Administrator to commercially operate the DJI Inspire 1& Phantom 2 in the National Airspace 

System (NAS), and for an exemption from the requirements of 14 C.F.R §§ 5 61.101(e)(4) and (5), 61.315(a), 61.23(a), 

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

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

operation, Jeffrey Brock’s operation of the DJI Phantom 2 and Inspire 1 UAS meets the conditions of FMRA Section 333 

and therefore, will not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart

H.

Accordingly, Jeffrey Brock requests relief from Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & 

(b), as these sections set forth requirements for maintenance that only apply to aircraft with an airworthiness certificate. 

Jeffrey Brock submits that the requested relief is proper since an equivalent level of safety will be ensured. Jeffrey Brock

will use experienced personnel and 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, Phantom 2 Instruction Manual and DJI Inspire 1 Instruction Manual). Furthermore, Jeffrey Brock will document and 

maintain all maintenance records for the DJI Inspire 1 UAS & DJI Phantom 2 UAS.

Jeffrey Brock also seeks an exemption from the requirements of Section 91.121, entitled Altimeter Settings, as the DJI 

Inspire 1 and Phantom 2 UAs will not have a typical barometric altimeter onboard. However, altitude information of the 

DJI Inspire 1 and Phantom 2 UAs will be provided to the PIC via Global Positioning System (GPS) equipment and radio 

communications telemetry data link, which downlinks from the UAs to the GCS for active monitoring of the flight path. 

This altitude information, combined with Jeffrey Brock’s skilled operation of the DJI Inspire 1 UAS & Phantom 2 within 

visual line of sight, at or below 400 feet AGL, will ensure a level of safety equivalent to Section 91.121.

Jeffrey Brock also seeks an exemption from the requirements of Section 91.151(b), entitled Fuel requirements for flight 

in VFR conditions. Jeffrey Brock submits that safety will not be affected by operation of the DJI Inspire 1 and Phantom 2 

UAs during daylight hours in visual meteorological conditions (VMC) under visual flight rules (VFR), with enough battery 

power to fly for a total duration of approximately 15 minutes to the first point of intended landing and, assuming normal 

cruising speed, to fly after that for at least 5 minutes.

7

In accordance with 14 C.F.R. § 11.81, Jeffrey Brock provides the following information in support of its petition for 

exemption:
A. Name & Address Of The Petitioner.

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

Jeffrey Brock

206 Oconee Dr

Cohutta, Ga 30710

Tel: 706-264-1568

Email: jeff@webmizer.com

8

B. The Specific Sections Of 14 C.F.R. From Which Jeffrey Brock Seeks Exemption.

3. Jeffrey Brock Seeks Exemption From The Requirements Of Section 61.315(a).

(2) For compensation or hire.

(3) In furtherance of a business.-(ci) Jeffrey Brock 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.

5. Jeffrey Brock Exemption From The Requirements Of Section 91.121. Section 91.121, entitled Altimeter 

settings, subsection (a), states the following, in part:

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

the case may be, by reference to an altimeter that is set, when operating-

(1)Below 18,000 feet MSL, to-

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

miles of the aircraft;

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

current reported altimeter setting of an appropriate available station; or

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

an appropriate altimeter setting available before departure.

9

6. Jeffrey Brock 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.

7. Jeffrey Brock 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[.]

8. Jeffrey Brock From The Requirements Of Section 91.407(a)(1)

Section 91.407, entitled Operation after maintenance, preventive

maintenance, rebuilding, or alteration, subsection (a)(1), states the following:

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

rebuilding, or alteration unless-

(1)It has been approved for return to service by a person authorized under § 43.7 of this chapter[.]

(b) Jeffrey Brock Seeks Exemption From The Requirements Of Sections 91.409(a)(1) and 91.409(a)(2).

Section 91.409, entitled Inspections, subsection (a), states the following:

(a) Except as provided in paragraph (c) of this section, no person may operate an aircraft unless, within the 

preceding 12 calendar months, it has had -

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

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

(2)An inspection for the issuance of an airworthiness certificate in accordance 10 with part 21 of this 

chapter. 

10. Jeffrey Brock Exemption From The Requirements Of Sections 91.417(a) and 91.417(b).

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

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

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

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

progressive, and other required or approved inspections, as appropriate, for each aircraft (including the 

airframe) and each engine, propeller, rotor, and appliance of an aircraft. The records must include-

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

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

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

(2)Records containing the following information:

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

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

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

on a specified time basis.

(iv) The current inspection status of the aircraft, including the time since the last inspection required by 

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

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

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

directive involves recurring action, the time and date when the next action is required.
(vi) Copies of the forms prescribed by § 43.9(d) of this chapter for each 11 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 Jeffrey Brock Seeks And The Reason Jeffrey Brock Seeks The Relief. 

1.Extent Of Relief Jeffrey Brock Seeks And The Reason Jeffrey Brock Seeks Relief From Section 61.113(a) 

and (b). 

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

the extent necessary to allow a PIC holding a private pilot or higher level certificate, as well as a current and valid airman 

medical certificate, and who has met certain flight-hour and currency requirements, to conduct the proposed UAS flight 

operations for compensation or hire.

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

compensation or hire, act as PIC of an aircraft in connection with any business or employment if: (1) The flight is only 

incidental to that business or employment; and (2) The aircraft does not carry passengers or property for compensation 

or hire.

As set forth more fully below, Jeffrey Brock submits that an equivalent level of safety will be maintained because no PIC 

will be allowed to operate the DJI Inspire 1 or Phantom 2 UAS unless that PIC has met certain flight-hour and currency 

requirements, 12 demonstrating that the PIC is able to safely operate either the DJI Inspire 1 or Phantom 2 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, Jeffrey Brock submits that all flights of the DJI Inspire 1 and Phantom 2 UAS, conducted by the PIC pursuant to 

the grant of this Petition: 

(1) will be incidental to Jeffrey Brock business; and (2) will not carry passengers or property for compensation or hire.

(2) Extent Of Relief Jeffrey Brock Seeks And The Reason Jeffrey Brock Seeks Relief From Section 61.23(a).

Relief from Section 61.23(a), entitled Operations requiring a medical certificate:

Requirements and duration, is requested to the extent required to necessary to allow a PIC holding a 

sport pilot certificate or higher level certificate, as well as a current and valid driver’s license, to conduct 

the proposed UAS flight operations for compensation or hire.

This relief is requested since the limitations set forth in Section 61.23(a) otherwise require the PIC of any flight for 

compensation or hire to hold a comprehensive FAA issued medical certificate. In Exemption No. 11213 to Aeryon Labs, 

Inc., the FAA “finds that, because of the risk mitigations established in the conditions and limitations of this exemption, a 

person that holds a U.S. issued driver’s license who is operating a UAS will not adversely affect safety. The FAA is

granting relief from § 61.23(a) to allow any pilot that holds one of the pilot’s certificates discussed above to operate a 

UAS under this exemption with a U.S. issued driver’s license, in lieu of an FAA-issued medical certificate. 
14

4. Extent Of Relief Jeffrey Brock Seeks And Jeffrey Brock Seeks Relief From Section 91.7(a). 

Relief from Section 91.7(a) entitled Civil aircraft airworthiness, is requested to the extent required to allow Jeffrey Brock

to determine that the DJI Inspire 1 UAS & Phantom 2 are in airworthy condition prior to every flight by ensuring that the 

UAS is in compliance with the operating documents (i.e., the DJI Inspire 1 Maintenance Manual, Monthly Maintenance 

Log, and DJI Inspire 1 Instruction Manual & DJI Phantom 2 Instruction Manual).

Jeffrey Brock seeks the requested relief because the DJI Inspire 1 UAS & DJI Phantom do not require an airworthiness 

certificate in accordance with 14 C.F.R. Part 21, Subpart H. Therefore, Jeffrey Brock 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. 

5. Extent Of Relief Jeffrey Brock Seeks And The Reason Jeffrey Brock 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), Jeffrey Brock seeks the requested relief because the DJI Inspire 1 UA’s altimeter may be 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 & DJI Phantom 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. 

6. Extent Of Relief Jeffrey Brock Seeks And Jeffrey Brock Relief From Section 91.151(b).

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

to allow flights of the battery powered DJI Inspire 1 and Phantom 2 UAs during daylight hours in visual meteorological 

conditions (VMC), under visual flight rules (VFR), for a total duration of 15 minutes to the first point of intended landing 

and, assuming normal cruising speed, to fly after that for at least 5 minutes. Jeffrey Brock seeks the requested relief 

because without an exemption from Section 91.151(b), the flight time duration of the battery powered DJI Inspire 1 and 

Phantom 2 UAs will severely constrain the practicality of any aerial video or still photo flight operations that Jeffrey 

Brock proposes to conduct pursuant to this Petition.

Significantly, as set forth below, the technical specifications of the DJI Inspire 1and Phantom 2 UAS, the DJI Inspire 1 and 

Phantom 2 operating documents, and Jeffrey Brock’s proposed operating limitations, ensure that Jeffrey Brock will 

safely operate the battery powered DJI Inspire 1 and Phantom 2 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 15 minutes to the 

first point of intended landing and, assuming normal cruising speed, to fly after that for at least 5 minutes. 

16

7. Extent Of Relief Jeffrey Brock Seeks And The Reason Jeffrey Brock Seeks Relief From Sections 91.405(a), 91.407(a) 

(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b). 
Since Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) only apply to aircraft with an 

airworthiness certificate, Jeffrey Brock requests relief from these Sections because the DJI Inspire 1 and Phantom 2 UAS 

does not require airworthiness certificates. As set forth more fully below, the DJI Inspire 1 and Phantom 2 UAS meets 

the conditions of FMRA Section 333 for operation without an airworthiness certificate. Accordingly, Jeffrey Brock will 

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

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

Manual, Phantom 2 Maintenance Manual, Maintenance Log, Phantom 2 Instruction Manual, and DJI Inspire 1 Instruction 

Manual). Furthermore, Jeffrey Brock will document and maintain all maintenance records for the DJI Inspire 1 UAS. 

D. The Reasons Why Granting Jeffrey Brock 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 Jeffrey Brock to safely, efficiently, and 

economically conduct aerial video and photography of outdoor recreational facilities, real estate, special events, and 

landscapes over certain areas of the United States.

Additionally, use of the DJI Inspire 1 and Phantom 2 UAS will decrease congestion of the NAS, reduce pollution, 

and provide significant benefits to the economy. Notably, the benefits of Jeffrey Brock’s proposed operation of 

the DJI Inspire 1 and Phantom 2 UAS will be realized without implicating any privacy issues.

17

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

The DJI Inspire 1 and Phantom 2 UAS 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 and Phantom 2 UAS would 

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

life and property in the air and on the ground.

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

by arriving and departing aircraft will be reduced. The DJI Inspire 1 and Phantom 2 UAS do not require an airport to 

takeoff or land. Likewise, a reduction of manned aircraft conducting aerial video and photography missions would 

result in fewer aircraft that must be handled by air traffic control during the ground, takeoff, departure, arrival, and 

landing phases of flight operations.

2.The Public Will Benefit From The Safety And Efficiency Of The DJI Inspire 1 and Phantom 2 UAS. 

Conducting aerial acquisitions with the DJI Inspire 1 and Phantom 2 UAS, instead of manned aircraft, will greatly 

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

video and still photography flight operations. By using battery power and electric motors, the DJI Inspire 1 and 

Phantom 2 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 video and photography, 

while burning approximately 20-30 gallons per hour of leaded aviation fuel. The DJI Inspire 1 and Phantom 2 UAS, 

while reducing the carbon footprint of aerial acquisitions, also eliminates noise pollution, as the UASs are propelled 

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

18

By using the DJI Inspire 1 and Phantom 2 UAS to perform aerial acquisitions, the substantial risk to life and property in 

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

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

the DJI Inspire 1 and Phantom 2 UAS ( Inspire 1 weighing approximately 6.5 pounds maximum gross weights with a 

length of 17.3 inches, width of 17.7 inches, and with no fuel on board, and Phantom 2 even smaller and lighter), have 
less physical potential for collateral damage to life and property on the ground, and in the air, compared to the manned 

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

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

3.Performing Aerial Video and Photography Operations With The DJI Inspire 1 and Phantom 2 UAS Will Benefit The 

Economy. 

In addition to being safe and efficient, the DJI Inspire 1 and Phantom 2 are economical alternatives to using manned 

aircraft to conduct similar aerial operations. As such, operation of the DJI Inspire 1 and Phantom 2 UAS will allow United 

States based companies, like Jeffrey Brock, 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 and Phantom 2 UAS allows companies greater 

operational flexibility compared to manned aircraft, and provides such flexibility without the high operational cost of a 

traditional manned aircraft.

By operating the DJI Inspire 1 and Phantom 2 UAS, companies such as Jeffrey Brock, 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 and Phantom 2 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, Jeffrey Brock proposed 

operation of the DJI Inspire 1 and Phantom 2 UAS will not implicate any privacy issues. Specifically, the DJI Inspire 1 and 

Phantom 2 UAS will be operated only in compliance with the conditions set forth in any exemption granted under this 

petition. 

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 Jeffrey Brock Seeks Exemption. 

1. Reasons Why The DJI Inspire 1 and Phantom 2 UAs Meet The Conditions Of The FAA Modernization and Reform Act 

of 2012 (FMRA) Section 333. 

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

operation, Jeffrey Brock operation of the DJI Inspire 1 and Phantom 2 UAS meet the conditions of FMRA Section 333, 

and will not require an airworthiness certificate in accordance with 14 C.F.R. Part 21,

Subpart H.

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

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

pose a threat to national security.

Specifically, FMRA Section 333 states the following, in part: 

(a) In General.--Notwithstanding any other requirement of this subtitle, and not later than 180 days after 

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

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

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

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

Secretary shall determine, at a minimum-
(1) which types of unmanned aircraft systems, if any, as a result of their size, weight, speed, 

operational capability, proximity to airports and populated areas, and operation within visual 

line of sight do not create a hazard to users of the national airspace system or the public or pose 

a threat to national security; and 

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

under section 44704 of title 49, United States Code, is required for the operation of unmanned 

aircraft systems identified under paragraph (1). 

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

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

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

In seeking this exemption, Jeffrey Brock submits that the DJI Inspire 1 and Phantom 2 UAS can operate safely in the NAS 

pursuant to FMRA Section 333, as demonstrated by: 

(a) the characteristics of the DJI Inspire 1 and Phantom 2 UAS; 

(b) the pilot certification requirement; and 

(c) the specific operating limitations.

a.The Specifications Of The DJI Inspire 1 and Phantom 2 UAS Demonstrate Its Safe Characteristics. 

The DJI Inspire 1 and Phantom 2 UAS do 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 and Phantom 2 UAS. 

The technical specifications of the DJI Inspire 1 and Phantom 2 UAS are set forth by the DJI 

Inspire 1 and Phantom 2 Specifications and Data Sheet, attached hereto as Exhibit A. 

ii. The DJI Inspire 1 and Phantom 2 UAS Autonomous Flight And Navigation Modes Enable The UAS To 

Remain Within A Defined Operational Area. 

The DJI Inspire 1 and Phantom 2 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 

and Phantom 2 UAS is provided in the DJI Inspire 1 21

User Manual, attached hereto as Exhibit B.1, and Phantom 2 User Manual, attaches hereto as Exhibit B.2

iii. The DJI Inspire 1 and Phantom 2 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 and Phantom 2, the UAs will remain stationary, in flight, for 3 seconds or 

more. If, after 3 seconds, the DJI Inspire 1 or Phantom 2 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.

A complete description of the Failsafe Functions of the DJI Inspire 1 and Phantom 2 UAS are set forth in the DJI Inspire 1 

User Manual, attached hereto as B.1 and Phantom 2 User Manual, attached hereto as B.2

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 in the DJI Inspire 1 User Manual. DJI Inspire 1 User Manual is attached hereto as 

Exhibit B. 
b. Flight Operations Of DJI Inspire 1 and Phantom 2 UAS Are Limited To The Line Of Sight Of A 

Certificated Pilot in Command With A Safety Observer. 

Jeffrey Brock 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 and Phantom 2 UAS. 

Additionally, a safety observer will assist all pilots during flight. 

c. Flights Of DJI Inspire 1 and Phantom 2 UAS Will Be Conducted Pursuant To Specific Operating 

Limitations. 

In seeking this exemption, proposes to commercially operate DJI Inspire 1 and Phantom 2 UAS 

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

States, pursuant to the following specific operating limitations: 

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

the operating documents, rotorcraft UASs weighing less than 55 pounds maximum gross weight: DJI 

Inspire 1 and Phantom 2 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 video and photography. 

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

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

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

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

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

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

the PIC’s FAA-issued airman medical certificate. 

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

7. 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 UAS operations and 

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

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

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

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

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

responsibility to track such revisions and present updated and revised documents to the Administrator 

upon request. The operator must also present updated and revised documents if it petitions for 
extension or amendment to the grant of exemption. If the operator determines that any update or 

revision would affect the basis upon which the FAA granted the exemption, then the operator must 

petition for amendment to its grant of exemption. The FAA’s UAS Integration Office (AFS-80) may be 

contacted if questions arise regarding updates or revisions to the operating documents. 

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

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

from operating until the necessary maintenance has been performed and the UAS is found to be in a 

condition for safe flight. The Ground Control Station must be included in the preflight inspection. All 

maintenance and alterations must be properly documented in the aircraft records. 

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

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

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

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

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

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

replacement, inspection, and life limit requirements. 

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

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

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

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

to service. 

15.Each UASs 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. § 19.1. All operations 

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

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

visual flight rules (SVFR) are not authorized. 

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

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

obtained, and the operation is conducted in accordance with a NOTAM as required by the operator’s 
COA. The letter of agreement with the airport management must be made available to the 

Administrator upon request. 

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

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

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

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 (NOTAM) 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.F.R. part 47, and have identification (N- Number) markings in 

accordance with 14 C.F.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.F.R. 91.9 and 91.203 must be available to the PIC at the 

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

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

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. 

Jeffrey Brock 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 or Phantom 2 UAS unless that PIC has demonstrated, by 

meeting minimum flight-hour and currency requirements, that the PIC is able to safely operate the DJI Inspire 1 and 

Phantom 2 UAS in a manner consistent with the exemption, including evasive and emergency maneuvers and 

maintaining appropriate distances from people, vessels, vehicles and structures.

Considering Jeffrey Brock proposed area of operations, and the operating limitations set forth-above; the parallel nature 

of sport pilot aeronautical knowledge requirements to those of commercial pilot requirements (See Exemption No. 

11062); and the airmanship skills necessary to safely operate the DJI Inspire 1 and Phantom 2 UAS, Jeffrey Brock submits 

that the additional manned airmanship experience of a commercially certificated pilot would not correlate to the 

airmanship skills necessary for Jeffrey Brock 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).

Jeffrey Brock will not allow any PIC to operate the DJI Inspire 1 and Phantom 2 UAS unless that PIC has demonstrated, by 

meeting minimum flight-hour requirements or the DJI Inspire 1 and Phantom 2 UAS training and currency requirements, 

that the PIC is able to safely operate the DJI Inspire 1 and Phantom 2 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 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 Jeffrey Brock proposed operations. The 

Administrator has held that prior documented flight experience that was obtained in compliance with applicable 

regulations would ensure safe operations, stating as follows: 

In Exemption No. 11062, the FAA required that prior to conducting operations for the purpose of motion picture 

filming (or similar operations), the PIC must have accumulated and logged, in a manner consistent with 14 CFR 

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

multi-rotor UAS. Prior to operations under Exemption No. 11062, the PIC must also have accumulated and 

logged a minimum of 5 hours as a UAS pilot operating the same make and model of UAS to be used for 

operations under the exemption. For clarification, the FAA considers these minimum hour requirements to be 

inclusive rather than additive; i.e. 5 hours make and model time may be included in the 10 hours of multi-rotor 

time and the 10 hours may be included in the total 25 hours of UAS rotorcraft time. In addition to the hour 

requirements, the PIC must accomplish 3 takeoffs and landings in the preceding 90 days (for currency 
purposes). The FAA finds that at a minimum, the 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, Jeffrey Brock will ensure safe operations by not allowing any PIC to operate the DJI Inspire 1 and Phantom 2 

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

to safely operate the DJI Inspire 1 and Phantom 2 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, 

Jeffrey Brock will ensure that the DJI Inspire 1 and Phantom 2 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 and Phantom 2 UAS will be provided to the PIC via GPS equipment and a radio communications telemetry 

data link, which downlinks from the UAS to the GCS for active monitoring of the flight path and altitude. This altitude 

information, combined with Jeffrey Brock’s operation of the DJI Inspire 1 and Phantom 2 UAS within visual line of sight,

at or below 500 feet AGL, will ensure a level of safety equivalent to Section 91.121. The altitude information will be 

generated by GPS equipment installed onboard the aircraft. Prior to each flight, a zero altitude initiation point is 

automatically established by the 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 91.151(b) Would Not Adversely Affect Safety. 

A grant of this exemption would ensure an equivalent level of safety established by 14 C.F.R. Section 91.151(b) as a

result of (1) the technical specifications of the DJI Inspire 1 and Phantom 2 UAs; (2) the limitations on the proposed flight 

operations; and (3) the location of the proposed flight operations. Accordingly, Jeffrey Brock will ensure that it will safely 

operate the battery powered DJI Inspire 1 and Phantom 2 UAs during daylight hours in VFR conditions, with enough 

battery power to fly for a total duration of 15 minutes to the first point of intended landing and, assuming normal 

cruising speed, to fly after that for at least 5 minutes.

Here, as in Exemption No. 11109, the technical specifications of the DJI Inspire 1 and Phantom 2 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 and Phantom 2 UAS 

provide audible and visual warnings to the PIC at the GCS when the UAs experiences low battery voltage, the first 
warning occurring at approximately 30% remaining battery power, and again at approximately 15% remaining battery 

power. At the critically low battery level, the DJI Inspire 1 and Phantom 2 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, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 

11160, 11161). 

6. Reasons Why An Exemption From The Requirements Of Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), 

And 91.417(a) & (b) Would Not Adversely Affect Safety.

In seeking this exemption, Jeffrey Brock submits that the equivalent level of safety with regard to the regulatory 

maintenance and alteration requirements established by Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 

91.417(a) & (b) will be met because Jeffrey Brock 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 DJI Inspire 1 Maintenance Manual, Phantom 2 Maintenance Manual, Monthly Maintenance Log, 

Phantom 2 Instruction Manual, and DJI Inspire 1 Instruction Manual). Furthermore, Jeffrey Brock will document and 

maintain all maintenance records for the DJI Inspire 1 and Phantom 2 UAS.

Since the DJI Inspire 1 and Phantom 2 UAS will be inspected as prescribed by the operating documents, Jeffrey Brock will 

maintain the equivalent level of safety established by Sections 91.405(a), 91.409(a)(1), and 91.409(a)(2). A copy of the 

DJI Inspire 1 User Manuals are attached hereto as Exhibit B.1; a copy of the Phantom 2 User Manual is attached hereto 

as Exhibit B.2, a copy of the DJI Inspire 1 Maintenance Manual is attached hereto as Exhibit C; a copy of the DJI Inspire 1 

UAS Maintenance LOG is attached hereto as Exhibit D.

Likewise, the exemption sought will not adversely affect safety because Jeffrey Brock 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 and Phantom 2 UAS will be performed by trained 

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

Significantly, previous exemptions granted by the FAA concerning Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), 

and 91.417(a) & (b) establish that safety is not adversely affected when the technical characteristics and operating 

limitations of the UAS are considered.

In consideration of Jeffrey Brock proposed operating limitations, the operating documents, and the technical aspects of 

the DJI Inspire 1 and Phantom 2 UAS, Jeffrey Brock submits that safety will not be adversely affected by granting 

exemption from 14 C.F.R. Sections 91.405(a), 91.407(a)(1) and (a)(2), 91.409(a)(2), and 91.417(a) and (b). The FAA has 

previously granted relief specific to UAS in circumstances similar, in all material respects, to those presented herein (e.g. 

Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112, 11136, 11138, 11150, 11153, 

11156, 11157, 11158, 11159, 11160, 11161). 

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

In accordance with Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA) and 14 C.F.R. § 21.16 entitled 

Special Conditions, Jeffrey Brock requests that the FAA prescribe special conditions for the intended operation of the DJI 

Inspire 1 and Phantom 2 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 video and photography over certain areas of the 

United States for compensation or hire. FMRA Section 333 sets forth the requirements for considering whether a UAS 

will create a hazard to users of the NAS or the public, or otherwise pose a threat to national security; and further, 

provides the 32 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 and Phantom 2 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 do not contain adequate or appropriate 

safety standards for an aircraft, aircraft engine, or propeller because of a novel or unusual design feature of the 

aircraft, aircraft engine or propeller, he prescribes special conditions and amendments thereto for the product. 

The special conditions are issued in accordance with Part 11 of this chapter and contain such safety standards 

for the aircraft, aircraft engine or propeller as the FAA finds necessary to establish a level of safety equivalent to 

that established in the regulations. 

See 14 C.F.R. § 21.16.

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

for Leading Edge’s intended operation of the DJI Inspire 1and Phantom 2 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)(1), 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 Jeffrey Brock Seeks 

Exemption: 

Jeffrey Brock seeks exemption from the requirements of 14 C.F.R Sections 61.101(e)(4) and (5), 61.315(a), 

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

A Brief Description Of The Nature Of The Exemption Jeffrey Brock Seeks:

This exemption will permit Jeffrey Brock to commercially operate an Unmanned Aircraft System (UAS) for the purpose of 

conducting aerial video and photography over certain areas of the United States.

G. Any Additional Information, Views, Or Arguments Available To Support Jeffrey Brock’s Request.

This Petition is made pursuant to the FAA Modernization and Reform Act of 2012 (FMRA) Section 333, which directs the 

Secretary of Transportation to determine if certain UAS may operate safely in the NAS. As such, Jeffrey Brock request for 

exemption may be granted pursuant to the authority of FMRA Section 333 and 14 C.F.R. Part 11, as set forth above.

FMRA Section 333 sets forth the requirements for considering whether a UAS will create a hazard to users of the NAS or 

the public, or otherwise pose a threat to national security; and further, provides the authority for such UAS to operate 

without airworthiness certification.

As discussed in detail above, Jeffrey Brock will operate the DJI Inspire 1 and Phantom 2 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, Jeffrey Brock seeks an exemption pursuant to 14 C.F.R § 11.61 and Section 333 of the FAA 

Modernization and Reform Act of 2012 (FMRA), which will permit safe operation of the DJI Inspire 1 and Phantom 2 UAS 

commercially, without an airworthiness certificate, for the limited purpose of conducting aerial video and photography 

over certain areas of the United States. By granting this Petition, the FAA Administrator will be fulfilling the 

Congressional mandate of the FAA Modernization and Reform Act of 2012, while also advancing the interests of the 

public, by allowing Jeffrey Brock to safely, efficiently, and economically operate the DJI Inspire 1 and Phantom 2 UAS 34 

commercially within the NAS.

WHEREFORE, in accordance with the Federal Aviation Regulations and the FAA Modernization and Reform Act of 2012, 

Section 333, Jeffrey Brock respectfully requests that the Administrator grant this Petition for an exemption from the 

requirements of 14 C.F.R Sections 61.101(e)(4) and (5), 61.315(a), 61.23(a), 91.7(a), 91.121, 91.151(b), 91.405(a), 

91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b), and permit Jeffrey Brock to operate the DJI Inspire 1 and 

Phantom 2 UAS commercially for the purpose of conducting aerial video and photography over areas of the United 

States.

Dated: 20 October, 2015

Respectfully submitted,

Jeffrey Brock

206 Oconee Dr

Cohutta, Ga 30710

706-264-1568

email – jeff@webmizer.com

Exhibits:

Exhibits: 

A – DJI Inspire 1 and Phantom 2 Specifications Data Sheet 

B.1– DJI Inspire 1 Manufacturer’s User Manual B.2 – DJI Phantom 2 Manufacturer’s User Manual 

C – DJI Inspire 1 Maintenance Manual 

D – Monthly Maintenance Log
EXHIBIT – A

DJI Inspire 1 and Phantom 2 Specifications Data Sheet

DJI INSPIRE 1 TECHNICAL SPECIFICATIONS

Aircraft Model

T600 

Weight (Battery Included) 

2935 g 

Hovering Accuracy (GPS Mode)

Vertical: 0.5 m 

Horizontal: 2.5 m 

Max Angular Velocity

Pitch: 300°/s 

Yaw: 150°/s 

Max Tilt Angle
35° 

Max Ascent Speed

5 m/s 

Max Descent Speed

4 m/s 

Max Speed

22 m/s (ATTI mode, no wind) 

Max Flight Altitude

4500 m 

Max Wind Speed Resistance

10 m/s 

Max Flight Time 

Approximately 18 minutes 

Motor Model

DJI 3510 

Propeller Model

DJI 1345 

Indoor Hovering

Enabled by default 

Operating Temperature Range -10° to 40° C 

Diagonal Distance

559 to 581 mm 

Dimensions

438x451x301 mm

Gimbal Model

ZENMUSE X3 

Output Power (With Camera)

Static: 9 W

In Motion: 11 W 

Operating Current Station:

750 mA 

Motion: 900 mA 

Angular Vibration

Range ±0.03° 

Mounting

Detachable

Controllable Range

Pitch: -90° to +30°

Pan: ±320° 

Mechanical Range Pitch: -125° to +45° Pan: ±330° 

Max Controllable Speed Pitch:

120°/s Pan: 180°/s

Camera Name

X3 

Model

FC350 

Total Pixels

12.76M 

Effective Pixels
12.4M 

Image Max Size

4000x3000 

ISO Range

100-3200 (video) 

100-1600 (photo) 

Electronic Shutter Speed

8s - 1/8000s 

FOV (Field Of View)

94° 

CMOS

Sony EXMOR 1/2.3” 

Lens

20mm (35mm format equivalent)f/2.8 focus at ∞ 

9 Elements in 9 groups 

Anti-distortion 

Still Photography Modes

Single shoot 

Burst shooting: 3/5/7 frames 

Auto Exposure Bracketing (AEB): 3/5 bracketed frames at 

0.7EV Bias 

Time-lapse 

Video Recording Modes

UHD (4K): 4096x2160p24/25, 3840x2160p24/25/30 FHD: 

1920x1080p24/25/30/48/50/60 HD: 

1280x720p24/25/30/48/50/60 

Max Bitrate Of Video Storage 

60 Mbps 

Supported File Formats 

FAT32/exFAT Photo: JPEG, DNG Video: MP4/MOV 

(MPEG-4 AVC/H.264)

Supported SD Card Types

Micro SD Max capacity: 64 GB. Class 10 or UHS-1 rating 

required. 

Operating Temperature Range 

0° to 40° C

Remote Controller Name

C1 

Operating Frequency

922.7~927.7 MHz (Japan Only) 5.725~5.825 GHz 

2.400~2.483 GHz 

Transmitting Distance (Outdoor And Unobstructed) 

2 km 

EIRP

10dBm@900m, 

13dBm@5.8G, 

20dBm@2.4G 

Video Output Port

USB, 

mini-HDMI 

Power Supply

Built-in battery 
Charging

DJI charger 

Dual User Capability

Host-and-Slave connection 

Mobile Device Holder

Tablet or Phone 

Max Mobile Device Width

170mm 

Output Power

9 W 

Operating Temperature Range -10° to 40° C 

Storage Temperature Range

Less than 3 months: -20° to 45° C 

More than 3 months: 22° to 28° C 

Charging Temperature Range 0-40° C 

Battery

6000 mAh LiPo 2S

Charger Model

A14-100P1A 

Voltage

26.3 V 

Rated Power

100 W

Battery (Standard) Name

Intelligent Flight 

Battery Model

TB47 

Capacity

4500 mAh 

Voltage

22.2 V 

Battery Type

LiPo 6S High voltage battery 

Energy

99.9 Wh 

Net Weight

570 g 

Operating Temperature Range -10° to 40° C 

Storage Temperature Range

Less than 3 months: -20° to 45° C 

More than 3 months: 

22° C to 28° C 

Charging Temperature Range

0° to 40° C 

Max Charging Power

180 W
Vision Positioning Velocity Range Below

8 m/s (2 m above ground) 

Altitude Range

5-500 cm 

Operating Environment

Brightly lit (lux > 15) patterned surfaces 

Operating Range

0-250 cm

Phantom 2 specifications: 

Aircraft Weight (Battery & Propellers Included) 1000g Hover Accuracy (Ready To Fly) Vertical: 0.8m; Horizontal: 2.5m 

Max Yaw Angular Velocity 200°/s Max Tilt Angle 35° Max Ascent / Descent Speed Ascent: 6m/s; Descent: 2m/s Max 

Flight Speed 15m/s Diagonal Length 350mm Flight Time 25mins Take-Off Weight ≤1300g Operating Temperature -10°C ~ 

50°C Supported Battery: DJI Smart Battery Type: 3S LiPo Capacity: 5200mAh, 11.1V Charging Environment Range: 0°C to 

40°C Discharging Environment Range: -20°C to 50°C 2.4GHz Remote Control Operating Frequency:2.4GHz ISM 

Communication Distance (Open Area) 1000m Receiver Sensitivity (1%PER) -97dBm Working Current/Voltage 120 

mA@3.7V Built-In LiPo Battery Working Current/Capacity 3.7V, 2000mAh

Exhibits: A – DJI Inspire 1 and Phantom 2 Specifications Data Sheet B.1– DJI Inspire 1 Manufacturer’s User Manual B.2 

– DJI Phantom 2 Manufacturer’s User Manual C – DJI Inspire 1 Maintenance Manual D – Monthly Maintenance Log

EXHIBIT – B.1

DJI Inspire 1 Manufacturer’s User Manual

Exhibits: A – DJI Inspire 1 and Phantom 2 Specifications Data Sheet B.1– DJI Inspire 1 Manufacturer’s User Manual B.2 

– DJI Phantom 2 Manufacturer’s User Manual C – DJI Inspire 1 Maintenance Manual D – Monthly Maintenance Log

Exhibit – C

DJI Inspire 1 Maintenance Manual

Exhibits: A – DJI Inspire 1 and Phantom 2 Specifications Data Sheet B.1– DJI Inspire 1 Manufacturer’s User Manual B.2 

– DJI Phantom 2 Manufacturer’s User Manual C – DJI Inspire 1 Maintenance Manual D – Monthly Maintenance Log
EXHIBIT – D

Monthly Maintenance Log

Month ___________

Year _____________

UAS # Issue Discovered Date Repaired Description & Maint Performed By

Software Update

Airframe

Engines

Propellers

Camera Gimble

Landing Gear

Other

Jeffrey Brock

206 Oconee Dr 

Cohutta, Ga 30710

706-264-1568

jeff@webmizer.com