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Linehan & Associates, LLC

UNITED STATES OF AMERICA 

DEPARTMENT OF TRANSPORTATION 

FEDERAL AVIATION ADMINISTRATION 

WASHINGTON, D.C.

Regulatory Docket No. _______________

IN THE MATTER OF THE PETITION FOR EXEMPTION OF: 

LINEHAN & ASSOCIATES, LLC

FOR AN EXEMPTION SEEKING RELIEF FROM THE REQUIREMENTS 

OF TITLE 14 OF THE CODE OF FEDERAL REGULATIONS SECTIONS 

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 

THE DJI INSPIRE 1 UNMANNED AIRCRAFT SYSTEM PURSUANT TO 

SECTION 333 OF THE FAA MODERNIZATION AND REFORM ACT OF 

2012 (PUBLIC LAW 112-95)

Submitted on July 21, 2015

Linehan & Associates, LLC

4025 S. 224th Cir, Elkhorn, Ne 68022
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TABLE OF CONTENTS

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

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

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

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

BASIS FOR PETITION......................................................................................................................6

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

THE SPECIFIC SECTIONS OF 14 C.F.R. FROM WHICH 

LINEHAN & ASSOCIATES SEEKS EXEMPTION................................................................7

THE EXTENT OF RELIEF LINEHAN & ASSOCIATES SEEKS AND 

THE REASON LINEHAN & ASSOCIATES SEEKS THE RELIEF......................................10

THE REASONS WHY GRANTING LINEHAN & ASSOCIATES

REQUEST WOULD BE IN THE PUBLIC INTEREST ........................................................12

THE REASONS WHY GRANTING THE EXEMPTION WOULD 

NOT ADVERSELY AFFECT SAFETY................................................................................14

SUMMARY THAT CAN BE PUBLISHED IN THE 

FEDERAL REGISTER..................................................................................................22

ANY ADDITIONAL INFORMATION, VIEWS, OR 

ARGUMENTS AVAILABLE TO SUPPORT LINEHAN & ASSOCIATES

REQUEST...........................................................................................................................22

REQUEST FOR BLANKET COA APPROVAL....................................................................23

CONCLUSION.................................................................................................................................23

APPENDIX A - DJI INSPIRE 1 TECHNICAL SPECIFICATIONS....................................................24

APPENDIX B - DJI INSPIRE 1 MANUFACTURER’S USER MANUAL...........................................26

APPENDIX C - MONTHLY MAINTENANCE LOG...........................................................................27
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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
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SUMMARY

Linehan & Associates, LLC seeks exemption from the requirements of 14 C.F.R §§ 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 Linehan & Associates, LLC to operate an Unmanned 

Aircraft System (UAS) for the commercial purpose of conducting aerial video and photography for 

broadcast production, motion picture filming, non profit promotional videos, multi-media 

presentations and internet based video production over certain areas of the United States.

INTRODUCTION AND INTERESTS OF THE PETITIONER

Linehan & Associates, LLC (hereinafter referred to as “Linehan & Associates”) provides it’s clients 

with expertise and knowledge in solutions to increase efficiency, productivity and effectiveness. 

Linehan & Associates provides clients with the highest quality digital content for use in broadcast, 

commercial, personal, and non-profit projects. Linehan & Associates has been in business for over 

2 years and has professional and first had experience flying military and civilian aircraft as a FAA 

commercial rated pilot. Linehan & Associates has over 1,000 flight hours in airplanes, helicopters, 

and tiltrotor aircraft with zero flight mishaps or incidents. Linehan & Associates has experience in 

public media relations and is recognized as an expert this field. The objective of Linehan & 

Associates aerial video operations is to provide high quality imaging for a variety of broadcast, 

commercial, and nonprofit productions, specifically targeting: • Broadcast Television Production • 

Motion Picture Filming • Non Profit Promotional Videos • Multi-media Presentations • Internet 

Based Video Production • Increase public knowledge of UAS and promote safe UAS operations.

BACKGROUND

Unmanned Aircraft System: DJI Inspire 1 UAS / sUA

Linehan & Associates seeks to operate DJI systems for compensation by having a FAA certified 

commercial pilot who will fallow all rules and regulations as the pilot in command within the NAS

according to the current FAR/AIM. The DJI Inspire 1 is a vertical takeoff and landing (VTOL) 

Unmanned Aircraft (UA) with a Ground Control Station (GCS) utilizing electronic tablet or smart 

phone systems. The DJI Inspire 1 has a maximum gross weight of 6 pounds 7.5 ounces, a length 

of 17.3 inches, width of 17.7 inches, height of 11.8 inches, and a maximum speed of approximately 

42 knots. The DJI Inspire 1 UA is equipped with four main rotors; driven by Lithium Polymer battery 

powered electric motors.

The DJI Inspire 1 UA that will be operated by Linehan & Associates will be registered in 
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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.

BASIS FOR PETITION
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Petitioner, Linehan & Associates 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 UAS in the National Airspace System (NAS), and for an exemption from 

the requirements of 14 C.F.R §§ 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, Linehan & Associates operation of the DJI 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, Linehan & Associates 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.

Linehan & Associates submits that the requested relief is proper since an equivalent level of safety 

will be ensured. Linehan & Associates will use experienced personnel or 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, and DJI 

Inspire 1 Instruction Manual). Furthermore, Linehan & Associates will document and maintain all 

maintenance records for the DJI Inspire 1 UAS.

Linehan & Associates seeks relief from Section 91.7(a), entitled Civil aircraft airworthiness, 

because the Inspire 1 UAS does not require an airworthiness certificate in accordance with 14 

C.F.R. Part 21, Subpart H. As such, Linehan & Associates submits that the operator will ensure 

that the DJI Inspire 1 UAS is in an airworthy condition, prior to every flight, by determining that the 

UAS is in compliance with the operating documents (i.e., Monthly Maintenance Log, and DJI 

Inspire 1 Instruction Manual), and that the aircraft is in a condition for safe flight.

Linehan & Associates also seeks an exemption from the requirements of Section 91.121, entitled 

Altimeter Settings, as DJI Inspire 1 UA does not have a typical barometric altimeter onboard. 

However, altitude information of the DJI Inspire 1UAs will be provided to the PIC via Global 

Positioning System (GPS) equipment and radio communications telemetry data link, which 

downlinks from the UA to the GCS for active monitoring of the flight path. This altitude information, 

combined with Linehan & Associates operation of the DJI Inspire 1 UAS within visual line of sight, 

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

Additionally, Linehan & Associates seeks an exemption from the requirements of Section 91.151(b), 

entitled Fuel requirements for flight in VFR conditions. Linehan & Associates submits that safety 

will not be affected by operation of the DJI Inspire 1 UA during daylight hours in visual 
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meteorological conditions (VMC) under visual flight rules (VFR), with enough battery power to fly 

for a total duration of approximately 13.5 minutes to the first point of intended landing and, 

assuming normal cruising speed, to fly after that for at least 4.5 minutes.

In accordance with 14 C.F.R. § 11.81, Linehan & Associates provides the following information in 

support of its petition for exemption:

A. Name And Address Of The Petitioner.

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

Patrick B. Linehan

Linehan & Associates, LLC 

4025 S. 224th Cir, Elkhorn, Ne 68022

Tel: (402) 902-9419

B. The Specific Sections Of 14 C.F.R. from Which Linehan & Associates Seeks 

Exemption.

1. Linehan & Associates 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.

2. Linehan & Associates Seeks 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.

3. Linehan & Associates Seeks 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.

4. Linehan & Associates Seeks Exemption From The Requirement Of Section 
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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[.]

5. Linehan & Associates Seeks Exemption 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[.]

6. Linehan & Associates 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 with part 21 of this 

chapter.

7. Linehan & Associates Seeks 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 
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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 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.
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C. The Extent Of Relief Linehan & Associates Seeks And The Reason Linehan & 

Associates Seeks That Relief.

1. Extent Of Relief Linehan & Associates Seeks And The Reason Linehan & 

Associates 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 Linehan & Associates to determine that the DJI Inspire 1 UAS is in airworthy condition 

prior to every flight by ensuring that the UAS is in compliance with the operating documents (i.e., 

the Linehan & Associates Aerial Operations Manual, Monthly Maintenance Log, and DJI Inspire 1 

Instruction Manual).

Linehan & Associates seeks the requested relief because the DJI Inspire 1 UAS does not require 

an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. Therefore,

Linehan & Associates will ensure that the DJI Inspire 1 UAS is 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.

2. Extent Of Relief Linehan & Associates Seeks And The Reason Linehan & 

Associates 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 utilizes 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),

Linehan & Associates 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. 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 UA is 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.

3. Extent Of Relief Linehan & Associates Seeks And The Reason Linehan & 

Associates Seeks 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 UA during daylight hours 

in visual meteorological conditions (VMC), under visual flight rules (VFR), for a total duration of 

13.5 minutes to the first point of intended landing and, assuming normal cruising speed, to fly after 
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that for at least 4.5 minutes. Linehan & Associates seeks the requested relief because without an 

exemption from Section 91.151(b), the flight time duration of the battery powered DJI Inspire 1 UA 

will severely constrain the practicality of any aerial video or still photo flight operations that Linehan 

& Associates proposes to conduct pursuant to this Petition.

Significantly, as set forth below, the technical specifications of DJI Inspire 1 operating documents, 

and Linehan & Associates proposed operating limitations, ensure that Linehan & Associates will 

safely operate the battery powered DJI Inspire 1 UA during daylight hours in visual meteorological 

conditions (VMC), under visual flight rules (VFR), with enough battery power to fly for a total 

duration of 13.5 minutes to the first point of intended landing and, assuming normal cruising speed, 

to fly after that for at least 4.5 minutes.

4. Extent Of Relief Linehan & Associates Seeks And The Reason Linehan & 

Associates 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, Linehan & Associates requests relief from these Sections 

because the DJI Inspire 1 UAS does not require airworthiness certificates. As set forth more fully 

below, the DJI Inspire 1 UAS meets the conditions of FMRA Section 333 for operation without an 

airworthiness certificate. Accordingly, Linehan & Associates will use trained technicians to perform 

maintenance, alterations, or preventive maintenance on the UAS using the methods, techniques, 

and practices prescribed in the UAS operating documents (i.e., Monthly Maintenance Log, and DJI 

Inspire 1 Instruction Manual). Furthermore, Linehan & Associates will document and maintain all 

maintenance records for the DJI Inspire 1 UAS.
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D. The Reasons Why Granting Linehan & Associates 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 Linehan & Associates to 

safely, efficiently, and economically perform aerial video and photography for TV broadcast, 

industrial, non profit, multi-media, special events, documentary and feature film production over 

certain areas of the United States.

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

and provide significant benefits to the economy. Notably, the benefits of Linehan & Associates’s 

proposed operation of the DJI Inspire 1 UAS will be realized without implicating any privacy issues.

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

The DJI Inspire 1 UA is battery powered and serves 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 the DJI 

Inspire 1 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 UA does 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 

UASs.

Conducting aerial acquisitions with the DJI Inspire 1 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 UAS produces 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 UA, while reducing the carbon footprint of aerial 

acquisitions, also eliminates noise pollution, as the UA is propelled by battery powered electric 

motors, rather than an internal combustion engine.

By using the DJI Inspire 1 UASs 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 UA (weighing approximately 6 

pounds 7.5 ounces, at it’s maximum gross weights with a length of 17.3 inches, width of 17.7 

inches, and with no fuel on board), has 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, 
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a length of 34 feet, and a fuel capacity of 180 gallons).

3. Performing Aerial Video and Photography Operations With The DJI Inspire 1 

UAS Will Benefit The Economy.

In addition to being safe and efficient, the DJI Inspire 1 UAS is also an economical alternative to 

using manned aircraft to conduct similar aerial operations. As such, operation of the DJI Inspire 1 

UAS will allow United States based companies, like Linehan & Associates, 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 UAS is one such technology that not only 

allows companies greater operational flexibility compared to manned aircraft, but provides such 

flexibility without the high operational cost of a traditional manned aircraft.

By operating the DJI Inspire 1 UAS, companies such as Linehan & Associates, 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 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, 

Linehan & Associates proposed operation of the DJI Inspire 1 UAS will not implicate any privacy 

issues. Specifically, the DJI Inspire 1 UAS will be operated only in compliance with operating 

documents (i.e., the Linehan & Associates Aerial Operations Manual, Monthly Maintenance Log, 

and DJI Inspire 1 Instruction Manual) which requires property owner involvement as well as local 

law enforcement notification, and in accordance with the Federal Aviation Regulations, including 

the minimum altitude requirements of 14 C.F.R. § 91.119.
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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 Linehan & Associates Seeks 

Exemption.

1. Reasons Why DJI Inspire 1 UA 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, Linehan & Associates operation of the DJI Inspire 1 UAS 

meets 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, Linehan & Associates submits that the DJI Inspire 1 UAS can operate 

safely in the NAS pursuant to FMRA Section 333, as demonstrated by: (a) the characteristics of the 

DJI Inspire 1 UAS; (b) the pilot certification requirement; and (c) the specific operating limitations.

a. The Specifications Of The DJI Inspire 1 UASs Demonstrate Its Safe 
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Characteristics.

The DJI Inspire 1 UASs 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 UASs.

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

Specifications and Data Sheet, attached hereto as Appendix A.

ii. The DJI Inspire 1 UAS Autonomous Flight And Navigation Modes Enable The 

UASs To Remain Within A Defined Operational Area.

The DJI Inspire 1 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 UAS is provided at 

pages 45-50 of the DJI Inspire 1 User Manual, attached hereto as Appendix B.

iii. The DJI Inspire 1 UAS Is 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 UA will remain stationary, in flight, for 3 seconds or 

more. If, after 3 seconds, the DJI Inspire 1 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 at pages 13 through 15 of the DJI Inspire 

1 User Manual, attached hereto as Appendix B.

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 at pages 40 through 48 of the DJI Inspire 1 User Manual. DJI Inspire 1 

User Manuals is attached here to as Appendix B.

b. Flight Operations Of DJI Inspire 1 UAS Are Limited To The Line Of Sight Of 

A Certificated Pilot in Command With A Safety Observer.

Linehan & Associates 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 UAS. Additionally, a 

safety observer will assist all pilots during flight time.

c. Flights Of DJI Inspire 1 UAS Will Be Conducted Pursuant To Specific 

Operating Limitations.

In seeking this exemption, Linehan & Associates proposes to commercially operate the DJI Inspire 

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

United States, pursuant to the following specific operating limitations:
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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 Unmanned Aircraft Systems. 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 44 knots.

4. The UA 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 
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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 UAS 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. § 1.1. 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 
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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 
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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 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, Linehan & Associates will ensure that the DJI Inspire 1 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).

3. 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 UA will be provided to the PIC via GPS equipment and a 

radio communications telemetry data link, which downlinks from the UA to the GCS for active 

monitoring of the flight path and altitude. This altitude information, combined with Linehan & 

Associates operation of the DJI Inspire 1 UA 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 UAS’s 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, 
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11064, 11065, 11066, 11067, 11080, 11109, 11112, 11136, 11138, 11150, 11153, 11156, 11157, 

11158, 11159, 11160, 11161).

4. 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 UAS; (2) the 

limitations on the proposed flight operations; and (3) the location of the proposed flight operations. 

Accordingly, Linehan & Associates will ensure that it will safely operate the battery powered DJI 

Inspire 1 UA during daylight hours in VFR conditions, with enough battery power to fly for a total 

duration of 13.5 minutes to the first point of intended landing and, assuming normal cruising speed, 

to fly after that for at least 4.5 minutes.

Here, as in Exemption No. 11109, the technical specifications of the DJI Inspire 1 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 UAS provides audible and visual warnings to the PIC at 

the GCS when the UA experiences low battery voltage, the first warning occurring at approximately 

30% remaining battery power, and again at approximately 10% remaining battery power. At the 

critically low battery level, the DJI Inspire 1 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).

5. 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, Linehan & Associates 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 Linehan & 

Associates will use trained technicians to perform maintenance, alterations, or preventive 

maintenance on the UASs using the methods, techniques, and practices prescribed in the 

operating documents (i.e., the Linehan & Associates Aerial Operations Manual, Monthly 

Maintenance Log, and DJI Inspire 1 Instruction Manual). Furthermore, Linehan & Associates will 

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

Since the DJI Inspire 1 UAS will be inspected as prescribed by the operating documents, Linehan 

& Associates 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 DJI Inspire 1 User Manuals are attached hereto as 

Appendix B; a copy of the DJI Inspire 1 UAS Maintenance LOG is attached hereto as Appendix C.
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Likewise, the exemption sought will not adversely affect safety because Linehan & Associates 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 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 Linehan & Associates proposed operating limitations, the operating documents, 

and the technical aspects of the DJI Inspire 1 UAS, Linehan & Associates 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).

6. 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, Linehan & Associates requests that the FAA prescribe 

special conditions for the intended operation of the DJI Inspire 1 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 §§ 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 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 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
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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 Linehan & Associates intended operation of the DJI Inspire 1 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, 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. Summary That Can Be Published In The Federal Register, stating: 

The Rules From Which Linehan & Associates Seeks Exemption: Linehan & 

Associates seeks exemption from the requirements of 14 C.F.R Sections 

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 Linehan & 

Associates Seeks: This exemption will permit Linehan & Associates 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 

Linehan & Associates 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, Linehan & Associates 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, Linehan & Associates will operate the DJI Inspire 1 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.
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H. Request for Blanket COA Approval

On March 24, 2015, the FAA announced that it has implemented a new policy of granting "blanket" 

COAs to applicants requesting exemptions from the Federal Aviation Regulations under Section 

333 of the FAA Modernization and Reform Act of 2012. The Applicant hereby requests that a 

"blanket" COA that conforms to the terms set forth in 

https://www.faa.gov/news/updates/?newsId=82245 upon approval of Linehan & Associates

exemption request.

CONCLUSION

As set forth herein, Linehan & Associates 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 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 

Linehan & Associates to safely, efficiently, and economically operate the DJI Inspire 1 UAS 

commercially within the NAS.

WHEREFORE, in accordance with the Federal Aviation Regulations and the FAA Modernization 

and Reform Act of 2012, Section 333, Linehan & Associates respectfully requests that the 

Administrator grant this Petition for an exemption from the requirements of 14 C.F.R Sections 

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 Linehan & Associates to operate the DJI Inspire 1 UAS commercially for the purpose of 

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

Thank you for working on this request. I personally believe it is important to integrate small UASs 

into the NAS. I also believe it is critical to have pilots who know the FAR/AIM and have a 

professional working knowledge of commercial aviation particularly if flying for compensation. As a 

commercial rated pilot with many hours of experience in single engine airplanes, single and multi 

engine helicopters, and multi engine tiltrotor (VTOL aircraft) I have a robust understanding or 

aviation safety and experiance. 

I do appreciate the FAA’s efforts to address the needs of this industry and their work towards 

finding a way to safely integrate this incredible technology into NAS.

Respectfully submitted,

Patrick B. Linehan (Linehan & Associates), 

4025 S. 224th Cir, Elkhorn, Ne 68022
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APPENDIX – A DJI INSPIRE 1 TECHNICAL SPECIFICATIONS

Linehan & Associates only utilizes safe and reliable UASs. DJI is an industry leader in small UAS 

production. DJI UASs are loaded with ground breaking software enabling the user to set 

parameters which will not allow flight into controlled airspace. Parameters can also be set to limit 

flight to no higher than a predetermined and set altitude as well as limit flight to a predetermined 

and set distance. In addition, DJI software provides real-time altitude and location information to 

the PIC via the linked monitor (smart phone/tablet devices)

1.1 DJI Inspire

1.1.1 Aircraft 

1.1.1.1 Model – T600

1.1.1.2 Weight (Battery Included) – 6lbs 7.5291oz (2935g) 

1.1.1.3 Hovering Accuracy (GPS Mode) – Vertical: 0.5m; Horizontal: 2.5m 

1.1.1.4 Max Angular Velocity – Pitch: 300deg./s; Yaw: 150deg./s 

1.1.1.5 Max Tilt Angle ‐ 35deg.

1.1.1.6 Max Ascent Speed – 5m/s 

1.1.1.7 Max Descent Speed – 4m/s 

1.1.1.8 Max Speed – 22m/s (ATTI mode, no wind – NOT RECOMMENDED) 

1.1.1.9 Max Flight Altitude – 4500m 

1.1.1.10 Max Wind Resistance – 10m/s 

1.1.1.11 Max Flight Time – Approximately 18 minutes 

1.1.1.12 Motor Model – DJI 3510 

1.1.1.13 Propeller Model – DJI 1345 

1.1.1.14 Operating Temperature Range – 14F to 104F (‐10C to 40C) 

1.1.1.15 Dimensions – 171/4” x 173/4” x 12”

1.1.2 Gimbal 

1.1.2.1 Model – ZENMUSE X3 

1.1.2.2 Output Power (with camera) – Static: 9W; In Motion: 11W 

1.1.2.3 Operating Current – Static: 750mA; In Motion: 900mA 

1.1.2.4 Angular Vibration Range ‐ Å0.03 deg

1.1.2.5 Mounting – Detachable 

1.1.2.6 Controllable Range – Pitch: ‐90deg to +30deg; Pan: Å320deg

1.1.2.7 Mechanical Range – Pitch: ‐125deg to 45 deg; Pan: Å330 deg

1.1.2.8 Max Controllable Speed – Pitch: 120 deg /s; Pan: 180 deg /s

1.1.3 Camera 

1.1.3.1 Name – X3

1.1.3.2 Model – FC350

1.1.3.3 Total Pixels – 12.76M

1.1.3.4 Effective Pixels – 12.4M

1.1.3.5 Image Max Size – 4000x3000

1.1.3.6 ISO Range – 100--‐3200
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1.1.3.7 Field of View ‐ 94deg.

1.1.3.8 CMOS – Sony EXMOR 1/2.3” 

1.1.3.9 HD Video Recording – UHD(4K): 4096x2160p24/25, 3840x2160p

24/25/30; FHD:1920x1080p 24/25/30/48/50/60;

1.1.3.10 Operating Temperature Range: 32F ‐ 104F (0C - 40C)

1.1.4 Transmitter 

1.1.4.1 Name – C1

1.1.4.2 Operating Frequency: 5.728--‐5.850GHz; 2.400--‐2.483GHz 

1.1.4.3 Communicating Distance (unobstructed): 2000m 

1.1.4.4 Output Power: 9W 

1.1.4.5 Operating Temperature Range: 14F to 104F (‐10C to 40C) 

1.1.4.6 Battery: 600mAh LiPo 2S 32
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APPENDIX – B

DJI INSPIRE 1 MANUFACTURER’S USER MANUAL

Most current version of the user manual can be found at:

http://www.dji.com/product/inspire-1/download
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APPENDIX – C Linehan & Associates Monthly Maintenance Log