US Department of Transportation UAS 

FAA Exemption Request

Colter Larsen 

1737 NE Lotus Dr. #2 Bend, Oregon 97701 

(307) 752-4053 

followingsimplicity@gmail.com

Dear Sir or Madam,

This petition is being submitted on my behalf without legal counsel or consulting services. 

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

and 14 C.F.R. Part 11, Colter Larsen, a freelance multimedia producer, hereby applies for an 

exemption from the Federal Aviation Regulations (FARs) listed below to allow operation of our 

Small Unmanned Aircraft System (sUAS) commercially in airspace regulated by the Federal 

Aviation Administration (FAA) so long as such operations are conducted with and under the 

conditions outlined herein or as may be established by the FAA as required by Section 333. 

All following request and subject matter is regarding a DJI Inspire 1. UAS system specifications 

are attached along with photo(s). 

The requested exemption would permit Colter Larsen to pursue his commercial interests in 

providing services to clients using a small Unmanned Aerial Vehicle (sUAV) in the following 

areas: Aerial data collection and Infrastructure inspection. Colter Larsen states that all sUAS 

flights over private will be with the property owner's consent and that of those who have 

consented or otherwise have agreed to be within the UAS’ radius during filming and photography 

applications. All flights will be carried out in visual line of sight with a ceiling under 400 feet 

(AGL) along with an observer. 

Colter Larsen has demonstrated the ability to safely and effectively fly the sUAS DJI Inspire 1 

which will be used for all commercial and private purposes. Colter Larsen complies with local 

ordinances and laws regarding the operation of sUAS, and adheres to all weather and 

environmental restrictions or limitations in reference to the operations of sUAS. Colter Larsen is 

also an FAA registered private rotorcraft pilot. The Inspire 1 being used was registered with the 

FAA on March 4th, 2016.

All flights will occur in ordinance with any state or local laws regarding privacy.

I, Colter Larsen, am seeking the exemption because I am committed to complying with all of the 

rules, guidelines, limitations, and future legislation set forth by the FAA. I agree to operate the 

sUAS in the manner that I have described, and for the purposes that I have described. Without 

the exemption request granted, I would be unable to safely and effectively run my business, and 

it is my intention to comply with the FAA and obtain an exemption of the following regulations.
Regulations from which exemption is requested: 

14 C.F.R. Part 21 

14 C.F.R. 61.113(a) & (b) 

14 C.F.R. 91.7(a) 

14 C.F.R. 91.9(b) (2) 

14 C.F.R. 91.103(b)

14 C.F.R. 91.109 

14 C.F.R. 91.119 

14 C.F.R. 91.121 

14 C.F.R. 91.151(a) 

14 C.F.R. 91.203(a) & (b) 

14 C.F.R. 91.205(b) 

14 C.F.R. 91.215 

14 C.F.R. 91.405 - 91.417(a) & (b)

I respectfully request an exemption from the following regulations with which I cannot fully

comply.

• 14 C.F.R. Part 21 (subpart H) "prescribes the procedural requirements for issuing and 

changing design approval, production approval, airworthiness certificates and airworthiness 

approval." (Summation from Exemption No. 11138, page 11) 

Response: "The Secretary of Transportation has determined that this aircraft meets the 

conditions of Section 333. Therefore, the FAA finds that the requested relief from 14 CFR 

part 21, and any associated noise certification and testing requirements of part 36, is not 

necessary." (Summation from Exemption No. 11138, page 11)

Equivalent Level of Safety: With extensive pre-flight and post flight inspections and 

maintenance performed to the User Manual specifications, the UAV will remain safe for 

operation.

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

states the following: (a) no person who holds a private pilot certificate may act as pilot in 

command of any aircraft that is carrying passengers of property for compensation or hire; nor 

may that person, for compensation or hire, act as pilot in command of an aircraft. (b) a private 

pilot may, for compensation or hire, act as pilot in command 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. 

Response: Organized or commercially available FAA-approved flight training has yet to be 

achieved by the UAV industry. Therefore requiring the exemption. 
Equivalent Level of Safety: My training consists of operations within a secure location, free 

from dense traffic and uninvolved individuals. Before the UAV leaves the ground into a 

hover a GPS systems check will be performed along with the registration of a Return-ToHome point in case of the rare & unfortunate event of a lost signal.

• 14 C.F.R. § 91.7(a): Civil Aircraft Airworthiness which states the following: (a) No person 

may operate a civil aircraft unless it is in an airworthy condition. 6 (b) The pilot in command of 

a civil aircraft is responsible for determining whether that aircraft is in condition for safe flight. 

The pilot in command shall discontinue the flight when unairworthy mechanical, electrical, or 

structural conditions occur.

Response: I respectfully request the exemption as the Inspire 1 will not be issued a valid 

airworthiness certificate.

Equivalent Level of Safety: With extensive pre-flight and post flight inspections and 

maintenance performed to the User Manual specifications, the UAV will remain safe for 

operation.

• 14 C.F.R. § Section 91.9 entitled Civil aircraft flight manual, marking, and placard 

requirements, subsection (b) states the following: (b) No person may operate a U.S. -registered 

civil aircraft-- (1) For which an Airplane or Rotorcraft Flight Manual is required by § 21.15 of 

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

Flight Manual or the manual provided for in § 121l141(b); and (2) For which an Airplane or 

Rotorcraft Flight Manual is not 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. 

Response: The Inspire 1 lacks the capability of carrying an approved flight manual onboard. 

Since all flight crew members are located at the ground control station rather than within the 

UAV, this holds no validity or importance.

Equivalent Level of Safety: The flight crew will be trained on the necessary information 

regarding the User Manual and will have the user manual readily available if needed.

• 14 C.F.R. Part 91.103 entitled Preflight Action, subsection (b)(1) states the following: in 

pertinent part, that each pilot in command shall, before beginning a flight, become familiar 

with all available information concerning the flight, to include, "For any flight, runway lengths 

at airports of intended use, and the following takeoff and landing distance information:...For 

civil aircraft for which an approved Airplane or Rotorcraft Flight Manual containing takeoff 

and landing distance data is required, the takeoff and landing distance data contained therein."

Response: Since the UAV can be safely operated without the need for the knowledge of 

runway lengths along with takeoff and landing distances, this will not pertain. I respectfully 

ask for an exemption.
Equivalent Level of Safety: The PIC will remain in strict adherence of completing the preflight checklist along with performing all inspections and taking actions required to assure 

that both the UAS and the operating environment are suitable for safe operations prior to 

launch.

• 14 C.F.R. Part 91.109 entitled Flight Instruction; Simulated Instrument Flight and Certain 

Flight Tests, subsection (a) states the following: No person may operate a civil aircraft (except 

a manned free balloon) that is being used for flight instruction unless that aircraft has fully 

functional dual controls. However, instrument flight instruction may be given in an airplane 

that is equipped with a single, functioning throwover control wheel that controls the elevator 

and ailerons, in place of fixed, dual controls, when -... 

Response: Since the Inspire 1 is unmanned & remotely piloted and is not equipped with dual 

controls on board, I respectfully ask for an exemption.

Equivalent Level of Safety: Instruction can be given through a ground based master and 

slave controller system which allows a safe & seamless exchange of controls. Training flights 

will be performed in a secure environment free from dense traffic and uninvolved 

individuals.

• 14 C.F.R. Part 91.119 entitled Minimum Safe Altitudes: General, states the following: in 

pertinent part, that except when necessary for takeoff or landing, no person may operate an 

aircraft below the following altitudes: (c) Over other than congested areas. An altitude of 500 

feet above the surface, except over open water or sparsely populated areas. In those cases, the 

aircraft may not be operated closer than 500 feet to any person, vessel, vehicle, or structure.

Response: Most UAVs are required to fly below the listed altitudes. Their weight and speed 

along with GPS Return-To-Home features usually mitigate incidents that could occur from 

loss of signal. In comparison to manned aircraft, the UAV carries no fuel or humans aboard, 

much lighter and has a much smaller footprint in the rare event of loosing the production of 

lift. Some flight missions may require the subject to be close but only with the permission of 

the owner and/or representatives consent. I respectfully request an exemption from this 

regulation.

Equivalent Level of Safety: The PIC and flight crew will be aware of mission objectives 

while preforming their pre-flight procedures and identify possible environmental hazards 

before launch.

• 14 C.F.R. Part 91.121 entitled Altimeter Settings, subsection (a) states the following: in 

pertinent part, that 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 

-... 

Response: The Inspire 1 cannot fully comply with the altitude requirements. The Inspire 1 

has a barometric altimeter which calculates the departure zone altitude as 0 feet above ground 

level. This altimeter is unable to be adjusted. However, the altitude will continuously be 
updated throughout the flight reporting its altitude in feet from its initial point of departure. I 

respectfully request an exemption from this regulation.

Equivalent Level of Safety: Just as it is in a manned aircraft, monitoring altitude will be part 

of the PICs scan.

• 14 C.F.R. Part 91.151(a) entitled Fuel Requirements For Flights in VFR Conditions, 

subsection (a) states the following: (a) in pertinent part, that 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. 

Response: Since the Inspire 1 uses lithium polymer batteries as its source of energy and 

flight times averaging 15 minutes, it won’t be possible to carry a 30 minute reserve. I 

respectfully request an exemption from this regulation.

Equivalent Level of Safety: Just as it is in a manned aircraft, monitoring fuel consumption 

or in this case battery levels, will be part of the PICs scan. An alarm also sounds at 30% 

capacity allowing the PIC to make informed mission decisions.

• 14 C.F.R. Part 91.203(a) and 91.203(b) entitled Civil Aircraft: Certifications Required, 

subsections (a) and (b) state the following: (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. Each U.S. airworthiness certificate used to comply with this 

subparagraph (except a special flight permit, a copy of the applicable operations specifications 

issued under § 21.197(c) of this chapter, appropriate sections of the air carrier manual required 

by parts 121 and 135 of this chapter containing that portion of the operations specifications 

issued under § 21.197(c), or an authorization under § 91.611 must have on it the registration 

number assigned to the aircraft under part 47 of this chapter. However, the airworthiness 

certificate need not have on it an assigned special identification number before 10 days after the 

number is first affixed to the aircraft. A revised airworthiness certificate having on it an 

assigned special identification number, that has been affixed to an aircraft, may only be 

obtained upon application to an FAA Flight Standards District Office ("FSDO"). (2) An 

effective U.S. registration certificate issued to its owner or, for operation within the United 

States, the second copy of the Aircraft registration Application as provided for in § 47.31(c), or 

a registration certification issued under the laws of a foreign country. (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 in the cabin or 

cockpit entrance so it is legible to passengers and crew. 

Response: The Inspire 1 is unmanned and has no cabin, cockpit, pilot station or entrances 

thereto. Therefore, no passengers can be carried and the flight crew is located at the ground 

control station. The Petitioner has previously requested relief from the requirements of 14 

C.F.R. § 91.7(a): Civil Aircraft Airworthiness in this submittal.
Equivalent Level of Safety: All the required documentation will be readily available to the 

flight crew at the ground control station.

• 14 C.F.R. Part 91.405(a) entitled Maintenance, Preventive Maintenance, Alterations, 

subsection (a) states the following: in pertinent part, that an aircraft operator or owner shall 

have the aircraft inspected as prescribed in subpart E of the same part and shall, between 

required inspections, except as provided in paragraph (c) of the same section, have 

discrepancies repaired as prescribed in Part 43 of the chapter. 

Response: The maintenance regarding the Inspire 1 is relatively simple and sometimes 

incredibly quick. With extensive pre and post flight procedures carried out by the PIC, the 

UAV can quickly be determined if it is safe and airworthy. If the UAV is rendered 

unairworthy, there is no room aboard the aircraft for placard designating it is unairworthy. I 

respectfully request an exemption from this regulation.

Equivalent Level of Safety: Replacement of minor parts will be performed by the PIC and if 

PIC determines that the fix can’t be resolved easily, or be a safety concern on a future flight, 

the UAV will be repaired by a manufacturer approved repair center.

• 14 C.F.R. Part 91.407(a)(1) & (b) entitled Operation after Maintenance, preventive 

maintenance, rebuilding, or alteration, subsection (a) (1) states the following: 8 in pertinent 

part, any person from operating an aircraft that has undergone maintenance unless it has been 

approved for return to service by a person authorized under § 43.7 of the same chapter. 

(b) No person may carry any person (other than crewmembers) in an aircraft that has been 

maintained, rebuilt, or altered in a manner that may have appreciably changed its flight 

characteristics or substantially affected its operation in flight until an appropriately rated pilot 

with at least a private pilot certificate flies the aircraft, makes an operational check of the 

maintenance performed or alteration made, and logs the flight in the aircraft records.

Response: Because the maintenance is straightforward on the Inspire 1, approval of flight 

after maintenance will be conducted by the PIC. Since the Inspire 1 cannot physically carry a 

pilot, crew or passengers, there won’t be any person aboard on flights after maintenance. I 

respectfully request an exemption from this regulation.

Equivalent Level of Safety: When maintenance is performed by the PIC. The PIC will also 

record the performed maintenance in a logbook. 

• 14 C.F.R. Part 91.409(a)(2) entitled Inspections, subsection (a)(2) states the following: in 

pertinent part, that no person may operate an aircraft unless, within the preceding 12 calendar 

months, it has had an inspection for the issuance of an airworthiness certificate in accordance 

with part 21 of this chapter. 

Response: There are no FAA approved protocols nor authorized inspection personnel. These 

issues will be carried out by the PIC. I respectfully request an exemption from this 

regulation.
Equivalent Level of Safety: All inspections will be thorough by the PIC whom will be 

educated on how to carry out an extensive inspection pre and post flight.

• 14 C.F.R. Part 91.417(a) and (b) entitled Maintenance Records, subsections (a) and (b) state 

the following: (a) 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 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 revisions 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 the chapter for each 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. 9 (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. 

Response: The details of this section would be impractical for an Inspire 1. I respectfully 

request an exemption from this regulation

Equivalent Level of Safety: When maintenance is performed it can be recorded into a 

logbook describing the maintenance performed.

This exemption would permit Colter Larsen to operate the DJI Inspire 1 for the purpose of aerial 

data collection and infrastructure inspection, while always operating under the premise that all 

aviation related accidents are preventable.
The PIC will assume these responsibilities:

1. Operations authorized by this grant of exemption are limited to the DJI Inspire 1 when 

weighing less than 55 pounds including payload. Proposed operations of any other aircraft 

will require a new petition or a petition to amend this exemption. 

2. Operations for the purpose of closed-set motion picture and television filming are not 

permitted. 

3. The UA may not be operated at a speed exceeding 87 knots (100 miles per hour). The 

exemption holder may use either groundspeed or calibrated airspeed to determine compliance 

with the 87 knot speed restriction. In no case will the UA be operated at airspeeds greater 

than the maximum UA operating airspeed recommended by the aircraft manufacturer. 

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

Altitude must be reported in feet AGL. 

5. The UA 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 or U.S. driver’s 

license. 

6. All operations must utilize a visual observer (VO). The UA must be operated within the 

visual line of sight (VLOS) of the PIC and VO at all times. The VO may be used to satisfy 

the VLOS requirement as long as the PIC always maintains VLOS capability. The VO 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 VO 

can perform the duties required of the VO. 

7. This exemption and all documents needed to operate the UAS and conduct its operations in 

accordance with the conditions and limitations stated in this grant of exemption, are 

hereinafter referred to as the operating documents. The operating documents must be 

accessible during UAS operations and made available to the Administrator upon request. If a 

discrepancy exists between the conditions and limitations in this exemption and the 

procedures outlined in the operating documents, the conditions and limitations herein take 

precedence and must be followed.

8. 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 prior to conducting further operations under this exemption. Functional 

test flights may only be conducted by a PIC with a VO and must remain at least 500 feet 
from other people. The functional test flight must be conducted in such a manner so as to not 

pose an undue hazard to persons and property. 

9. The operator is responsible for maintaining and inspecting the UAS to ensure that it is in a 

condition for safe operation. 

10. Prior to each flight, the PIC must conduct a pre-flight inspection and determine the UAS is in 

a condition for safe flight. The pre-flight inspection must account for all potential 

discrepancies, e.g., inoperable components, items, or equipment. 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. 

11. The operator must follow the UAS manufacturer’s maintenance, overhaul, replacement, 

inspection, and life limit requirements for the aircraft and aircraft components. 

12. Each UAS operated under this exemption must comply with all manufacturer safety 

bulletins. 

13. Under this grant of exemption, a PIC must hold either an airline transport, commercial, 

private, recreational, or sport pilot certificate. The PIC must also hold a current FAA airman 

medical certificate or a valid U.S. driver’s license issued by a state, the District of Columbia, 

Puerto Rico, a territory, a possession, or the Federal government. The PIC must also meet the 

flight review requirements specified in

14 CFR § 61.56 in an aircraft in which the PIC is rated on his or her pilot certificate. 

14. The operator may not permit any PIC to operate unless the PIC demonstrates the ability to 

safely operate the UAS in a manner consistent with how the UAS will be operated under this 

exemption, including evasive and emergency maneuvers and maintaining appropriate 

distances from persons, vessels, vehicles and structures. PIC qualification flight hours and 

currency must be logged in a manner consistent with

14 CFR § 61.51(b). Flights for the purposes of training the operator’s PICs and VOs 

(training, proficiency, and experience-building) and determining the PIC’s ability to safely 

operate the UAS in a manner consistent with how the UAS will be operated under this 

exemption are permitted under the terms of this 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 CFR § 91.119.
15. UAS operations may not be conducted during night, as defined in 14 CFR § 1.1. All 

operations must be conducted under visual meteorological conditions (VMC). Flights under 

special visual flight rules (SVFR) are not authorized. 

16. The UA may not operate within 5 nautical miles of an airport reference point (ARP) as 

denoted in the current FAA Airport/Facility Directory (AFD) or for airports not denoted with 

an ARP, the center of the airport symbol as denoted on the current FAA-published 

aeronautical chart, unless a letter of agreement with that airport’s management is obtained or 

otherwise permitted by a COA issued to the exemption holder. The letter of agreement with 

the airport management must be made available to the Administrator or any law enforcement 

official upon request. 

17. 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. 

18. If the UAS loses communications or loses its GPS signal, the UA must return to a predetermined location within the private or controlled-access property. 

19. The PIC must abort the flight in the event of unpredicted obstacles or emergencies. 

20. The PIC is prohibited from beginning a flight unless (considering wind and forecast weather 

conditions) there is enough available power for the UA to conduct the intended operation and 

to operate after that for at least five minutes or with the reserve power recommended by the 

manufacturer if greater. 

21. Air Traffic Organization (ATO) Certificate of Waiver or Authorization (COA). All operations 

shall be conducted in accordance with an ATO-issued COA. The exemption holder may 

apply for a new or amended COA if it intends to conduct operations that cannot be conducted 

under the terms of the attached COA. 

22. All aircraft operated in accordance with this exemption must be identified by serial number, 

registered in accordance with 14 CFR part 47, and have identification (N−Number) markings 

in accordance with 14 CFR part 45, Subpart C. Markings must be as large as practicable.

23. Documents used by the operator to ensure the safe operation and flight of the UAS and any 

documents required under 14 CFR §§ 91.9 and 91.203 must be available to the PIC at the 

Ground Control Station of the UAS any time the aircraft is operating.

These documents must be made available to the Administrator or any law enforcement 

official upon request. 

24. The UA must remain clear and give way to all manned aviation operations and activities at 

all times. 
25. The UAS may not be operated by the PIC from any moving device or vehicle. 

26. All Flight operations must be conducted at least 500 feet from all nonparticipating 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 in a manner ensuring the safety of nonparticipating persons; and b. The owner/

controller of any vessels, vehicles or structures has granted permission for operating closer to 

those objects 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. The PIC, VO, operator 

trainees or essential persons are not considered nonparticipating persons under this 

exemption.

27. All operations shall be conducted over private or controlled-access property with permission 

from the property owner/controller or authorized representative. Permission from property 

owner/controller or authorized representative will be obtained for each flight to be 

conducted. 

28. 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. If this exemption permits operations for the purpose of closed-set motion 

picture and television filming and production, the following additional conditions and 

limitations apply.

29. The operator must have a motion picture and television operations manual (MPTOM) as 

documented in this grant of exemption.

30. At least 3 days before aerial filming, the operator of the UAS affected by this exemption 

must submit a written Plan of Activities to the local Flight Standards District Office (FSDO) 

with jurisdiction over the area of proposed filming. The 3-day notification may be waived 

with the concurrence of the FSDO. The plan of activities must include at least the following: 

a. Dates and times for all flights;

b. Name and phone number of the operator for the UAS aerial filming conducted under this grant of 

exemption;

c. Name and phone number of the person responsible for the on-scene operation of the UAS;
d. Make, model, and serial or N-Number of UAS to be used;

e. Name and certificate number of UAS PICs involved in the aerial filming;

f. A statement that the operator has obtained permission from property owners and/or local officials 

to conduct the filming production event; the list of those who gave permission must be made 

available to the inspector upon request;

g. Signature of exemption holder or representative; and 

h. A description of the flight activity, including maps or diagrams of any area, city, town, country, 

and/or state over which filming will be conducted and the altitudes essential to accomplish the 

operation.

31. Flight operations may be conducted closer than 500 feet from participating persons 

consenting to be involved and necessary for the filming production, as specified in the 

exemption holder’s MPTOM.

Similar Exemptions

They are similar in all/or many material respects to relief previously requested in Grant of 

Exemption Nos. 11062, 11109, 11112, and 11213.

UAV Specifications

Model T600

Weight 6.4lbs

Max Speed 49 MPH

Max Service Ceiling 400ft AGL

Max Flight Time ~18 minutes

Public Benefit

Unmanned Aircraft System sUAVs are often seen as superior to helicopters as an aerial data 

gathering platform due to the smaller devices, cheaper equipment and personnel cost, reduced 

noise and as such, a much smaller environmental impact.
Safety Specifications

Colter Larsen is petitioning for an exemption to operate a DJI Inspire 1 with a built-in stabilized 

HD camera and GPS safety features which limit its ability of flight above ground level (AGL), to 

limit the radius of the distance it flies from the operator and to exclude it from operations within 

designated Class B, C and D airspace including a no-fly zone feature. 

The DJI Inspire 1 also has a failsafe function that is triggered in the event communication is lost 

between the sUAS and the main controller transmitter. At that time, the sUAS will return to its 

point of takeoff and land safely. If the connection is restored, the PIC can regain control of flight 

and land manually. 

These specifications meet with the Model Aircraft Operating Standards as set below:

• The petitioner will only operate its sUAS in line-of-sight of a pilot and/or observer and will 

operate at sites that are `sufficient distance' from populated areas within the sterile area 

described in the FOPM. Such operations will ensure that the sUAS will "not create a hazard to 

users of the national airspace system or the public." 

• When flying the sUAS within three (3) miles of an airport, airport operators will be notified 

and the operator will give the right-of-way to avoid flying in the proximity of full-scale 

aircraft. Maximum flight time for each operation will be 30 minutes. 

• Flights will be terminated when battery levels reach 25%, allowing sufficient reserve flight 

time to safely land the sUAS. 

• The sUAS will be programmed so it will not be operated at an altitude that exceeds 400 feet 

AGL, and not more than 200 feet above an elevated platform from which videography is 

planned. 

• Minimum crew for each operation shall consist of: sUAS pilot and a visual sUAS observer

• The sUAS PIC will be an FAA licensed airman holding a minimum of a Private Pilot certificate 

and a current FAA medical certificate. 

• The sUAS operated by the petitioner weighs less than 25 pounds, including all payload (i.e. 

camera, lens, and stabilized gimbal). 

• The sUAS will operate at speeds of no more than 50 knots, can hover, and can simultaneously 

move vertically and horizontally. 

I am prepared to modify or amend any part of this request to satisfy the need for an equivalent 

level of safety. I look forward to working with your office. Please contact me at any time if you 

require additional information or clarification.

UAS Inspire 1 specifications are listed below.

http://download.dji-innovations.com/downloads/inspire_1/en/

Inspire_1_User_Manual_v1.0_en.pdf
Respectfully, 

Colter Larsen