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October 31, 2015

U.S. Department of Transportation

Docket Operations, M-30

1200 New Jersey Avenue, SE

Room W12-140, West Building Ground Floor

Washington, DC 20590-0001

Re: Petition of DamianPitts, LLC DBA FlexRight Solutions for an Exemption Pursuant to 

Section 333 of the FAA Modernization and Reform Act of 2012 to Operate an 

Unmanned Aircraft System

Dear Sir or Madam:

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the Reform Act) 

and 14 C.F.R. Part 11, FlexRight Solutions hereby applies for an exemption from the Federal 

Aviation Regulations identified below to allow for the commercial operation of the DJI INSPIRE 

1 and the DJI PHANTOM 3 ADVANCED, both manufactured by DJI Innovations.

I. REGULATIONS FOR WHICH EXEMPTION IS REQUESTED

FlexRight Solutions requests exemption from the following regulations:

 14 C.F.R Part 21, Subpart H;

 14 C.F.R Part 27;

 14 C.F.R § 45.23(b);

 14 C.F.R. § 45.27(a);

 14 C.F.R § 61.113;

 14 C.F.R § 91.7(a);

 14 C.F.R § 91.9(b)(2);

 14 C.F.R § 91.9(c);

 14 C.F.R § 91.103;

 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) & (b)

 14 C.F.R § 91.203 (a) & (b);

 14 C.F.R § 91.405(a);

 14 C.F.R § 91.407(a)(l);

 14 C.F.R § 91.409(a)(2);

 14 C.F.R § 91.417 (a) & (b).

This petition incorporates the material contained in the DJI INSPIRE 1 User Manual and the DJI 

PHANTOM 3 ADVANCED User Manual (together, the “Manuals”). 
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II. STATUTORY AUTHORITY FOR REQUESTED EXEMPTIONS

This petition for exemption is submitted in accordance with Section 333 of the Reform Act. 

Congress has directed the FAA “to safely accelerate the integration of civil unmanned aircraft 

systems into the national airspace system.” Pursuant to Section 333 of the Reform Act, the FAA 

Administrator is to permit operation of an unmanned aircraft system where it does not create a 

hazard to users of the national airspace system (NAS) or the public or pose a threat to national 

security based on the following considerations:

 The size, weight, speed and operational capability;

 Operation in proximity to airports and populated areas; and

 Operation within visual line of sight of the operator.

Furthermore, the Federal Aviation Act grants the FAA Administrator general authority to grant 

exemptions from the agency’s safety regulations and minimum standards when the 

Administrator decides a requested exemption is in the public interest. See 49 U.S.C. §§ 

106(f), 44701-44716, et seq. A party requesting an exemption must explain the reasons why the 

exemption: (1) would benefit the public as a whole, and (2) would not adversely affect safety or 

how it would provide a level of safety at least equal to the existing rules. 14 C.F.R. § 11.81.

III. DESCRIPTION OF FLEXRIGHT SOLUTIONS

FlexRight Solutions is a consulting and training firm specializing in trending technologies for 

clients requiring such. Founded by a U.S. Marine and staffed with fighter pilots, law 

enforcement officers, and Judges, FlexRight Solutions maintains an impeccable record of 

upstanding business practices while adhering to the letter of the law. Training courses offered by 

FlexRight start with classroom understanding of FAA regulations and advisories, progress 

through safety and equipment teachings, and culminate in hands-on flight training of UAS. The 

student departs with a detailed knowledge of the industry, the law, and how to safely fly their 

UA. The company is headquartered in Oreland, Pennsylvania and currently maintains clients 

across the Eastern seaboard of the United States.

FlexRight shares the interests of the FAA regarding safety of the National Airspace System and

looks to set a new standard, ensuring every UAS operator gains the same level of knowledge, 

training, and respect for the airspace as a typical certificated, manned aircraft pilot.

The contact information for the petitioner, FlexRight Solutions, is as follows:

Dr. Damian D. Pitts

Chief Executive Officer

DamianPitts, LLC / FlexRight Solutions

2010 Paper Mill Road

Oreland, Pennsylvania 19075

(877) 838-3753

dpitts@flexrightsolutions.com
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IV. DESCRIPTION OF PROPOSED OPERATIONS

FlexRight Solutions is requesting exemption from applicable Federal Aviation Regulations 

(FARs) pursuant to Section 333 of the Modernization and Reform Act to perform the following:

o UAS Flight Training

o Aerial Inspection

o Aerial Photography and Videography

o UAS Equipment Demonstration

o Emergency Response

FlexRight Solutions recognizes the enormous potential of UAS but also recognizes the need for 

due diligence and responsibility on the part of the persons that will fly the UA to ensure the 

safety of the National Airspace with respect to manned aircraft and persons/property on the 

ground. FlexRight Solutions will assist with the integration of UAS into the NAS by educating 

users on this new technology. FlexRight Solutions is seeking this exemption to help ensure that 

both recreational users and public entity operators have a reasonable option for obtaining UAS 

flight and safety training.

A. UNMANNED AIRCRAFT SYSTEMS

FlexRight Solutions will operate the DJI Inspire 1 and the DJI Phantom 3 Advanced unmanned 

aircraft systems.

DJI INSPIRE 1:

Please see Attachment 1 for the DJI Inspire 1 User Manual

DJI PHANTOM 3 ADVANCED:

Please see Attachment 2 for the DJI Phantom 3 Advanced User Manual

The inherent safety features, sophistication, programmability, GPS navigation, Return To Home 

capability, Geofenced flight location restrictions, and restricted altitude feature, as well as 

differentiating radio frequency (RF) for aircraft controller/receiver and for the camera make both 

of these incredibly safe and reliable UAs for the purposes of this petition and the use of 

FlexRight Solutions.

B. PROPOSED OPERATIONS DEMONSTRATE EQUIVALENT LEVEL OF SAFETY

General Description of Proposed Flight Operations

FlexRight Solutions proposes to operate within the limitations and performance specifications 

listed in the Manuals provided by the manufacturer. These limitations provide for at least an 

equivalent, or higher, level of safety for operations under the current regulatory structure because 

the proposed operations represent a safety enhancement to the existing protocols.
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The proposed operations do not create any hazard to users of the national airspace system or pose 

a threat to national security. Each UA is a battery operated quadcopter with a maximum flight 

time of approximately 25 minutes. Each UA weighs less than 10 pounds. Neither UA has a 

groundspeed surpassing 50 mph and both will be operated at less than 200 feet AGL.

Manned aircraft are at risk of fuel spillage and fire in the event of an incident or accident. 

Neither UA in this petition carry any fuel, and therefore the risk of fire following an incident or 

accident due to fuel spillage is eliminated. Compared to manned aircraft, the unmanned aircraft 

being operated by the petitioner reduces the risk to participating persons and property in close 

proximity to the aircraft due to the limited size, weight, operating conditions, and design safety 

features of each UA.

The FAA has determined that the risk of not having an electronic means to monitor and 

communicate with other aircraft, such as transponders or sense and avoid technology, is 

mitigated by placing limits on altitude, requiring stand-off distance from clouds, permitting 

daytime operations only, and requiring that the aircraft be operated within visual line of sight and 

yield right of way to all other manned operations. Additionally, the operator will request a 

NOTAM prior to all operations to alert other users of the NAS.

Each UA has the capability to operate safely after experiencing certain in-flight failures. Both 

are also able to respond to a lost-link event with a pre-coordinated, predictable, automated flight 

maneuver, which returns the aircraft to a pre-determined and safe location.

1. Specific Limitations on Proposed Flight Operations

Given the small size involved, the restricted environment within which they will operate, the 

procedures listed below, and pilot certification requirements, FlexRight Solutions' proposed 

operations using unmanned aircraft would “not create a hazard to users of the national airspace 

system or the public or pose a threat to national security.” Reform Act Section 333(b)(1).

1. Each aircraft weighs less than ten (10) pounds.

2. Each aircraft will be identified by serial number, registered with the FAA, and 

have identification (N-Number) markings as large as practicable.

3. Flights will be operated within visual line of sight of the pilot in command (PIC).

4. Prior to each flight, a zero altitude initiation point will be established and 

confirmed for accuracy by PIC.

5. Maximum flight time for each operational flight will be 20 minutes.

6. The aircraft will be safely landed with no less than the greater of (a) 25% battery 

life remaining or (b) five minutes of flight time remaining.

7. The aircraft will be operated during daylight and in VFR conditions.

8. Flights will not exceed 200 feet AGL.

9. Flights will be operated at a lateral distance of at least 100 feet from any persons 

or property not associated with the operation having not given prior permission.

10. Flights will be limited to a groundspeed of 35 mph.

11. Minimum crew for each flight will consist of a PIC and an Observer.
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12. The PIC will possess at least a sport pilot certificate, private pilot certificate, or 

have held a US Army Military Occupational Specialty (MOS)15W Unmanned 

Aerial Vehicle Operator, USMC MOS 7314/7316 -- Unmanned Aerial Vehicle 

(UAV) Air Vehicle Operator, and/or 150U Tactical Unmanned Aerial Systems 

(TUAS) Operations Technician, Navy MOS NEC 8362, NEC 8363, NEC 8364, 

NEC 8366, NEC 8367, and NEC 8368. Pilots with this training are considered 

trained and currently fly throughout the United States for the United States 

military. Pilots with military training will be required to hold a security 

clearance. Having a government furnished security clearance ameliorates security 

concerns over civil UAS operations conducted in accordance with Section 333. 

13. Prior to the flight, a Mission Plan will be created setting forth the limitations for 

the flight as well as contact information for the PIC.

14. The flight operations will always and under all circumstances, yield the right of 

way to other manned aircraft operations.

15. FlexRight Solutions will provide NOTAM details to the FAA 24 hours prior to 

each flight operation.

16. All required permissions and permits will be obtained from territory, state, county 

or city jurisdictions prior to flight.

17. Prior to commencing operations, FlexRight Solutions will obtain a Certificate of 

Waiver or Authorization (COA) from the FAA.

18. If the aircraft loses communications, it will have the capability to return to a predetermined location within the operational area and land.

19. If the aircraft loses its GPS signal it will have the capability of being flown 

manually to a predetermined location within the operational area and land.

20. The flight will be aborted in case of unpredicted obstacles or emergencies or other 

environmental condition deemed unsafe.

21. Each flight will be recorded in an Operations Log Book.

24. Maintenance on the aircraft will be recorded in a Maintenance Log Book.

2. Flight Recovery, Lost Communications, and Lost GPS Procedures

The flight recovery, lost communications, and lost GPS procedures are documented above, and 

are more fully documented in the Manuals (See Attachment 1 & 2).

V. SPECIFIC FAR EXEMPTIONS REQUESTED

FlexRight Solutions seeks an exemption from several interrelated provisions of 14 C.F.R. Parts 

21, 45, 61, and 91 for purposes of conducting the requested operations using the DJI INSPIRE 1 

and DJI PHANTOM 3 ADVANCED. Listed below are (1) the specific FAR sections for which 

exemption is sought, and (2) the operating procedures and safeguards that FlexRight Solutions 

has established which will ensure a level of safety better than or equal to the rules from which 

exemption is sought. See 14 C.F.R. § 11.81 (e).
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A. 14 C.F.R. Part 21, Subpart H – Airworthiness Certificates and 14 C.F.R. 

§ 91.203(a)(1)

The FAA has stated that no exemption is needed from this section if a finding is made under the 

Reform Act that the UAS selected provides an equivalent level of safety when compared to 

aircraft normally used for the same application. These criteria are met, and therefore no 

exemption is needed. See Grant of Exemption to Astraeus Aerial, Docket No. FAA 2014-

0352 at 13-14, 22. If, however, the FAA determines that there are some characteristics of either 

UA that fail to meet the requirements of the Reform Act, an exemption is requested.

Equivalent Level of Safety: Both unmanned aircraft in this petition are safe when taking into 

account their size, weight, speed, and operational capability. Each weigh less than ten (10) 

pounds and will be flown at speeds less than 35 miles per hour, in visual line of sight of the 

operator, and in designated safe locations. Neither aircraft carries pilots, passengers, explosive 

materials, or flammable liquid fuels and each will be operated within the parameters of the 

Manuals.

FlexRight Solutions will also provide the FAA with advance notice of all operations via 

NOTAM and coordination with the local FSDO. The proposed operations will be at least as safe 

as, or safer than, conventional rotorcraft operating with an airworthiness certificate without the 

restrictions and conditions proposed here.

B. 14 C.F.R. Part 27 Airworthiness Standards: Normal Category Rotorcraft

14 C.F.R. Part 27 sets forth the procedural requirements for airworthiness certification of normal 

category rotorcraft. To the extent the UA in this petition would otherwise require certification 

under Part 27, FlexRight Solutions seeks an exemption from Part 27’s airworthiness standards 

for the same reasons identified in the request for exemption from 14 C.F.R. Part 21, Subpart H.

C. 14 C.F.R. §§ 45.23(b), 45.27(a) and 91.9(c): Aircraft Marking and 

Identification Requirements

14 C.F.R. §45.23(b), Markings of the Aircraft states:

When marks include only the Roman capital letter “N” and the registration number is displayed 

on limited, restricted or light-sport category aircraft or experimental or provisionally certificated 

aircraft, the operator must also display on that aircraft near each entrance to the cabin, cockpit, or 

pilot station, in letters not less than 2 inches nor more than 6 inches high, the words “limited,” 

“restricted,” “light-sport, “experimental,” or “provisional,” as applicable.

14 C.F.R. § 45.27(a) states:

Rotorcraft. Each operator of a rotorcraft must display on that rotorcraft horizontally on both 

surfaces of the cabin, fuselage, boom, or tail the marks required by § 45.23.
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14 C.F.R. § 91.9(c) states:

No person may operate a U.S.-registered civil aircraft unless that aircraft is identified in 

accordance with part 45 of this chapter.

In a previous Grant of Exemption, the FAA determined that exemption from these requirements 

was warranted provided that the aircraft “have identification (N-Number)markings in accordance 

with 14 CFR part 45, Subpart C if the markings are “as large as practicable.” See Exemption No. 

11062, Docket No. FAA 2014-0352, at p. 14.

Equivalent Level of Safety: FlexRight Solutions will mark all unmanned aircraft with their 

respective N- Number in a prominent spot on the fuselage with markings that are as large as 

practicable.

D. 14 C.F.R. § 61.113: Private Pilot Privileges and Limitations

FlexRight Solutions seeks exemption from 14 CFR § 61.113, which restricts private pilots from 

flying aircraft for compensation or hire and would also require a second class medical certificate. 

The purpose of Part 61 is to ensure that the skill and competency of any PIC matches the 

airspace in which the PIC will be operating, as well as requiring certifications if the pilot is 

carrying passengers or cargo for hire.

While the unmanned aircraft in this petition will be operated as part of a commercial operation, it 

carries neither passengers nor cargo. In the Grant of Exemption in FAA Docket No. FAA-2014-

0352, the FAA determined that the unique characteristics of UAS operation outside of controlled 

airspace did not warrant the additional cost and restrictions attendant with requiring the PIC to 

have a commercial pilot certificate and a class II medical certificate. The FAA has also 

determined that the required knowledge for a commercial pilot covers the same fundamental 

principles as a private pilot.

The PIC will possess at least a sport pilot certificate, private pilot certificate, a third class 

medical certificate, or have held a US Army Military Occupational Specialty (MOS)15W 

Unmanned Aerial Vehicle Operator, USMC MOS 7314/7316 -- Unmanned Aerial Vehicle 

(UAV) Air Vehicle Operator, and/or 150U Tactical Unmanned Aerial Systems (TUAS) 

Operations Technician, Navy MOS NEC 8362, NEC 8363, NEC 8364, NEC 8366, NEC 8367, 

and NEC 8368.

The FAA stated in its grant of an exception to Astraeus Aerial the “the FAA considers the 

overriding safety factor for the limited operations proposed by the petitioner to be the airmanship 

skills acquired through UAS-specific flight cycles, flight time, and specific make and model 

experience, culminating in verification through testing.” See Exemption No. 11062, Docket No. 

FAA 2014-0352, at p. 18. The proposed operations can achieve an equivalent level of safety by 

requiring the knowledge and experience in unmanned aircraft operations described above.
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Furthermore, the security screening conducted by the Transportation Security Administration of 

certificated airmen satisfies the statutory requirement of Section 333 for operations to not pose a 

threat to national security.

The restrictions FlexRight Solutions has placed on its UA operations meet or exceed the 

restrictions similarly imposed on Astraeus Aerial in FAA Docket No. FAA-2014-0352. 

FlexRight Solutions will operate in restricted areas (the sites) away from persons and property 

not involved in the operation. The aircraft will be flown based on VLOS at or below 200 feet 

AGL. A NOTAM will be issued at least 24 hours before the flight is to occur, and the flight will 

be coordinated with the applicable FSDO.

E. 14 C.F.R. § 91.7(a): Civil Aircraft Airworthiness

FlexRight Solutions seeks an exemption from 14 C.F.R. § 91.7(a), which requires that a civil 

aircraft be in airworthy condition to be operated. The FAA has stated that no exemption is 

required to the extent that the requirements of Part 21 are waived or found inapplicable. 

Accordingly, FlexRight Solutions requests that the requirements for Section 91.7 be treated in 

accordance with FAR Part 21 Subpart H. See Grant of Exemption No. 11062, p. 19.

F. 14 C.F.R. § 91.9(b)(2): Civil Aircraft Flight Manual in the Aircraft; 

14 C.F.R. §§ 91.203(a) and (b): Carrying Civil Aircraft Certification and 

Registration

Pursuant to 14 C.F.R. § 91.9(b)(2):

(b)No person may operate a U.S.-registered civil aircraft -

...

(2)For which an Airplane or Rotorcraft Flight Manual is required by § 21.5 of this 

chapter, unless there is available in the aircraft a current approved Airplane or 

Rotorcraft Flight Manual, approved manual material, markings, and placards, or 

any combination thereof.

Pursuant to 14 C.F.R. § 91.203(a) and (b):

(a)Except as provided in § 91.715, no person may operate a civil aircraft unless it has 

within it the following:

(1)An appropriate and current airworthiness certificate.

(b)No person may operate a civil aircraft unless the airworthiness certificate required by 

paragraph (a) of this section or a special flight authorization issued under § 91.715 is 

displayed at the cabin or cockpit entrance so that it is legible to passengers or crew.

FlexRight Solutions does not request an exemption from this section but instead notifies the FAA 

that, in accordance with FAA Office of Chief Counsel’s Opinion dated August 8, 2014, the UAS 
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flight manual, registration certificate and other documentation will be kept at the control station 

with the PIC during flight. The Chief Counsel’s Office has held that for all UAS operations, this 

alternate method constitutes full compliance with the regulations. See also Grant of Exemption 

No. 11062, pp. 19-20, and Grant of Exemption No. 8607.

G. 14 C.F.R. § 91.103: Preflight Action

FlexRight Solutions seeks an exemption from 14 C.F.R. § 91.103, which requires a PIC to 

become familiar with specific information before each flight, including information contained in 

the FAA-approved Flight Manual on board the aircraft. The aircraft will not have a Flight 

Manual on board. The PIC will take all actions including reviewing weather, flight battery 

requirements, landing and takeoff distances and aircraft performance data before initiation of 

flight. Under these circumstances, the FAA has stated that no exemption is required. See Grant 

of Exemption No. 11062, p. 20. An exemption is requested to the extent that an FAAapproved Flight Manual is required.

Equivalent Level of Safety: An equivalent level of safety will be provided by following the 

Manuals. The PIC will take all required preflight actions - including performing all required 

checklists and reviewing weather, flight requirements, battery charge, landing and takeoff 

distance, aircraft performance data, and contingency landing areas - before initiation of flight. 

The Manuals will be kept at the ground station with the operator at all times.

H. 14 C.F.R. § 91.109(a): Flight Instruction

FlexRight Solutions seeks an exemption from 14 C.F.R. § 91.109(a), which provides that “[n]o 

person may operate a civil aircraft (except a manned free balloon) that is being used for flight 

instruction unless that aircraft has fully functioning dual controls.” UASs and remotely piloted 

aircraft, by their design, do not have functional dual controls.

Equivalent Level of Safety: When flight instruction is performed, no pilots will be on the aircraft 

and the Ground Control Station will be a safe distance from the aircraft and the public, causing 

no safety hazard. Given the size and speed of the both unmanned aircraft in this petition, an 

equivalent level of safe training can still be performed without dual controls because no pilot or 

passengers are aboard the aircraft, and all persons will be a safe distance away in the event that 

the aircraft experiences any difficulties during flight instruction. In addition, FlexRight Solutions 

will conduct flight training at a secure location away from non-involved property or spectators 

and will comply with the provisions in the Manuals. Accordingly, FlexRight Solutions' proposed 

method of operation provides superior levels of safety.

I. 14 C.F.R. § 91.119(c): Minimum Safe Altitudes in Uncongested Areas

FlexRight Solutions requests an exemption from the minimum safe altitude requirements of 14 

C.F.R. § 91.119(c). Section 91.119(c) prescribes that an aircraft may not be operated closer than 

500 feet to any person, vessel, vehicle, or structure. The Manuals provide for operations away 

from congested populations areas on the sites. The FAA has already determined that relief from 
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Section 91.119(c) is warranted for UAS operations in areas with similar flight restrictions as 

those imposed by FlexRight Solutions. See Grant of Exemption No. 11062, p. 20-21.

Equivalent Level of Safety: Compared to flight operations with rotorcraft weighing far more 

than the maximum weights proposed herein, and given the lack of flammable fuel, any risk 

associated with these operations is far less than those that presently exist with conventional 

aircraft. An equivalent level of safety will be achieved given the size, weight, and speed of the 

UA, as well as the locations where it is operated. In order to avoid any risk to aircraft, flight 

operations will be restricted to 200 feet AGL or below. As set forth in the Manuals and herein, 

the PHANTOM will be operated away from persons or structures not involved in the operation. 

All persons who are not involved with FlexRight Solutions operations will be required to be at 

least 100 feet from the training perimeter. 

J. 14 C.F.R. § 91.121: Altimeter Settings

This petition seeks an exemption from 14 C.F.R. § 91.121, which requires a person operating an 

aircraft to maintain cruising altitude or flight level by reference to an altimeter that is set to the 

elevation of the departure airport. The unmanned aircraft in this petition use both barometric 

pressure sensors and GPS to determine altitude but does not have the ability to input a current 

altimeter setting. An exemption is required to the extent that each UA does not have a barometric 

altimeter setting. The altitude of the aircraft is monitored by the PIC using the Ground Control 

Station and by the Visual Observer.

Equivalent Level of Safety: The FAA has stated that an equivalent level of safety can be 

achieved if the aircraft will be operated at or below 400 feet AGL and within visual line-of-sight 

in addition to GPS based altitude information relayed in real time to the operator. See Grant of 

Exemption No. 11062, p. 20-21. As the attached Manuals indicate, both UA will be operated at 

or below 400 feet AGL and complies with the limitations in the Grant of Exemption No. 11062.

K. 14 C.F.R. § 91.151(a): Fuel Requirements for Flight in VFR Conditions

FlexRight Solutions requests an exemption from 14 C.F.R. § 91.151(a)’s fuel requirements for 

flight in VFR conditions. Section 91.151 states:

(a) No person may begin a flight in an airplane 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 –

(1) During the day, to fly after that for at least 30 minutes; or

(2) At night, to fly after that for at least 45 minutes.

Here, the technological limitations on the battery power of each UA in this petition means that 

no meaningful flight operations can be conducted while still maintaining a 30 minute reserve. 

The aircraft is battery powered with a maximum flight time of 25 minutes. FlexRight Solutions 

proposes that the maximum flight time for each operational flight will be 20 minutes. The
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aircraft will be safely landed with no less than the greater of (a) 25% battery life remaining or (b) 

five minutes of flight time remaining.

Equivalent Level of Safety: The FAA has stated that an equivalent level of safety is provided if 

the UAS flight is conducted under daytime VFR flight conditions using VLOS, and terminated 

with at least 25% reserve battery power still available. See Grant of Exemption No. 11062, p. 21-

22. FlexRight Solutions will be providing an equivalent level of safety by safely landing with no

less than the greater of (a) 25% battery life remaining or (b) five minutes of flight time remaining 

and otherwise complying with the flight restrictions above.

L. 14 C.F.R. §§ 91.405(a), 91.407(a)(l), 91.409(a)(2); 91.417(a) and 

(b): Maintenance Inspections

FlexRight Solutions seeks an exemption from the maintenance inspection requirements 

contained in 14 C.F.R. § 91.405(a), 91.407(a)(l), 91.409(a)(2); 91.417(a) and

(b). These regulations specify maintenance and inspection standards in reference to 14 C.F.R. 

Part 43. See, e.g., 14 C.F.R. § 91.405(a) (stating that each owner or operator of an aircraft 

“[s]hall have the aircraft inspected as prescribed in subpart E of this part and shall between 

required inspections ... have discrepancies repaired as prescribed in part 43 of this chapter”). An 

exemption from these regulations is needed because Part 43 and these sections only apply to 

aircraft with an airworthiness certificate, which neither UA in this petition will have.

Equivalent Level of Safety: An equivalent level of safety will be achieved because maintenance 

and inspections will be performed in accordance with the Manuals. This includes maintenance, 

overhaul, replacement, and inspection requirements for the aircraft and procedures to document 

and maintain maintenance records for the aircraft. This also includes preflight inspection 

procedures. See Exemption No. 11062, Docket No. FAA 2014- 0352, at p. 14-15.

As provided in the Manuals, flights will not be conducted unless a flight operations checklist is 

performed that includes all of the aircraft’s components. The Manuals also set requirements for 

maintenance log books and record keeping as well as routine and post-flight maintenance. The 

Manuals set requirements for both annual maintenance and preventative maintenance.

VI. PUBLIC INTEREST

Granting FlexRight Solutions' petition for exemption furthers the public interest. National policy 

set by Congress favors early integration of UAS into the NAS in controlled, safe working 

environments such as the environments proposed in this petition. By granting this petition, the 

FAA will fulfill Congress’s intent of allowing UAS to operate safely in the NAS before 

completion of the rulemaking required under Section 332 of the Reform Act.

Moreover, use of unmanned aircraft operations will improve awareness of FAA regulations and 

provide a standard level of training for all unmanned aircraft pilots. The use of the UA in this 

petition will also decrease safety-related incidents involving new users of unmanned aircraft.
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Thus, the use proposed here will allow FlexRight Solutions to determine the efficacy of the UA 

in this petition for increasing public safety. Each unmanned aircraft weighs less than ten (10)

pounds, carries no passengers or crew, and has no flammable fuel, as opposed to larger and more 

powerful helicopters and small airplanes. This program may prevent accidents and injuries, and 

there is a strong public interest in making these operations more safe and effective through the 

use of UASs.

VII. PRIVACY

All flights will occur over designated areas cleared with property owners. All flights will be 

conducted in accordance with any applicable federal, state or local laws regarding privacy.

VIII. SUMMARY FOR FEDERAL REGISTER

Pursuant to 14 C.F.R. Part 11, the following summary is provided for publication in the Federal 

Register, should it be determined that publication is needed:

DamianPitts, LLC DBA FlexRight Solutions seeks an exemption from the following rules for the 

commercial operation of small unmanned aircraft systems to perform UAS Flight Training, 

Aerial Photo and Video Service, Inspection, Equipment Demonstration, and Emergency 

Response Work: 14 C.F.R Part 21, Subpart H; 14 C.F.R Part 27; 14 C.F.R § 45.23(b); 14 C.F.R. 

§ 45.27(a); 14 C.F.R § 61.113; 14 C.F.R § 91.7(a); 14 C.F.R § 91.9(b)(2); 14 C.F.R § 91.9(c); 14 

C.F.R § 91.103; 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) & (b) 14 C.F.R § 91.203 (a) & (b); 14 C.F.R § 91.405(a); 14 C.F.R § 91.407(a)(l); 14 

C.F.R § 91.409(a)(2); 14 C.F.R § 91.417 (a) & (b).

The exemption will enhance safety by reducing risk to the operator, the general public and 

property owners.

IX. ATTACHMENTS

Attachment 1: DJI INSPIRE 1 User Manual v1.8

Attachment 2: DJI PHANTOM 3 ADVANCED User Manual v1.6

Attachment 3: DJI INSPIRE 1 Maintenance Manual v1.0

Attachment 4: DJI PHANTOM 3 ADVANCED Safety Guidelines and Disclaimer

Attachment 5: DamianPitts, LLC: Certificate of Organization
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