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August 31, 2015

U.S. Department of Transportation

Document Management System

1200 New Jersey Ave., SE

West Building Ground Floor, Room W12-140

Washington, D.C. 20590

Concerning: Unmanned Aircraft Systems (UAS)

Petition for Exemption

Section 333 of the FAA Modernization & Reform Act and Part 11 of the Federal 

Aviation Regulations from 14 CFR 61.23(a); 61.101(e)(4) and (5); 61.113(a); 91.119(c); 

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

Please Address all communications with respect to this Petition to:

Jason Thomas McGarraugh

Ghost Tracs Ventures LLC

1916 Trammel Drive 

Nolensville TN. 37135

Phone: 615-719-2972

Fax: 561-427-7255

Email: Jason@GhostTracs.com
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Petition for Exemption Summary

Dear Sir or Madam,

Pursuant to Section 33 of the FAA Modernization and Reform Act of 2012, and 14 CFR 

Part 11, Ghost Tracs Ventures L.L.C., an operator of an Unmanned Aircraft System 

(UAS) hereby applies for an exemption from the listed Federal Aviation Regulations 

(FAR’s) to allow commercial operation of its UAS.

Ghost Tracs Ventures L.L.C. is eligible for an exemption for film/television production, 

and aerial videography for TV, internet commercials, marketing, for the motion picture 

and television industry for scripted closed set filming, and search and rescue. 

Summary:

Type of UAS to be flown:

DJI Inspire 1 using the DJI A2 Flight Controller (Previously granted in 

Exemption #11252), and the DJI Inspire 1 airframe configuration (Previously granted in 

Exemption #11303 & #11279).

The operations will be for aerial videography, and photography for the motion picture 

and television industry (Exemption #11279), and for search and rescue operation

(Exemption #12654). 

DJI Inspire

o Aircraft Type: Multi-Rotor

o Construction: Carbon Fiber, plastic, aluminum

o Propulsion: Electric (4) Brushless, 3 phase, AC Motors.

o Onboard Electronics: A2 Flight Controller, manual control system, flight 

control system optics, still and video imager, 2.4/5.8 Ghz Lightbridge

o Launch Type: VTOL

o Landing Type: VTOL

o Launch Speed: 15 MPH Vertical

o Speed Envelope: 35 MPH Cruise, 0 MPH Stall

o Duration of Flight: 15 Minutes

o Aircraft Weight: 3.3 lbs./ (Empty)

Ghost Tracs LLCs request for exemption would be a Benefit to the Public:

The DJI Inspire 1 is designed to collect its imagery utilizing VTOL capabilities; where a 

fixed wing aircraft, or UA, could have difficulties in either take off or landing. The DJI 

Inspire 1 is equipped with a Return-To-Launch area (RTH) feature, which can be 

activated in the event of an emergency with the PIC, or UAS. The DJI Inspire 1 does not 

use internal combustion motors for propulsion, and does not carry any flammable liquids 

for operation. Risk to the public is further reduced by the DJI Inspire 1's ability to stay
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aloft while moving slowly, or to hover in place, unlike a fixed-wing aircraft, or UA,

which must continue lateral motion during flight. 

The Benefit to the Public is unquestionable. The use of manned aircraft is in many

instances much more expensive, and much more dangerous, than the operations proposed 

herein. Therefore, the operations presented in this summary are at least an equivalent 

level of safety under 14 CFR part 11. 

Extent of Relief:

Regulations from which the exemption is requested: 

o 14 C.F.R. § 61.23(a) 

o 14 C.F.R. § 61.101

o 14 C.F.R. § 61.113(a)

o 14 C.F.R. § 61.315

o 14 C.F.R. § 91.7(a)

o 14 C.F.R. § 91.119

o 14 C.F.R. § 91.121

o 14 C.F.R. § 91.151(a)(1)

o 14 C.F.R. § 91.405(a)

o 14 C.F.R. § 91.407(a)(1)

o 14 C.F.R. § 91.409(a)(1) & (2)

o 14 C.F.R. § 91.417(a) & (b)

This exemption application is expressly submitted to fulfill Congress' goal in passing 

Section 333(a) through (c) of the FAA Modernization and Reform Act of 2012. This law

directs the Secretary of Transportation to consider whether certain unmanned aircraft 

systems may operate safely in the national airspace system (NAS) before completion of 

the rulemaking required under Section 332 of the FAA Modernization and Reform Act. 

In making this determination, the Secretary is required to determine which types of UA 

do not create a hazard to users of the NAS or the public or pose a threat to national 

security in light of the following: (Exemption #12657)

o The UAS’s size, weight, speed, and operational capability;

o Operation of the UAS in close proximity to airports, and populated areas, 

and

o Operation of the UAS within visual line of sight of the operator (VLOS). 
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Aircraft Equivalent Level of Safety

Ghost Tracs LLC proposes that the exemption requested herein applies to civil aircraft 

that have the characteristics, and that operate with the limitations listed herein. These 

limitations provide for at least an equivalent or even higher level of safety to operations 

under the current regulatory structure. 

Ghost Tracs LLC agrees to be bound to FAA regulations when conducting commercial 

UAS operations. The list of limitations and conditions include the following: 

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

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 

permitted. 

3. Operations for the purpose of Search and Rescue are permitted. 

4. Operations for the purpose of aerial photography, and videography of real estate, 

sporting events, concerts, and other events are permitted as long as commercial UAS 

services were requested of Ghost Tracs LLC, and legal permission granted by the 

requestee; not superseding any FAA conditions, and limitations connected to this 

exemption. 

5. The UAS 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 UAS be operated at 

airspeeds greater than the maximum UAS operating airspeed recommended by the 

aircraft manufacturer. 

6. The UAS must be operated at an altitude of no more than 400 feet above ground level 

(AGL). Altitude must be reported in feet AGL. 

7. 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 or 

U.S. driver’s license. 

8. All operations must utilize a visual observer (VO). The UAS 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. 
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9. 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. 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 or any

law enforcement official upon request. The operator must also present updated and 

revised documents if it petitions for extension or amendment to this grant of exemption. 

If the operator determines that any update or revision would affect the basis upon which 

the FAA granted this exemption, then the operator must petition for an 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. 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. 

11. The operator is responsible for maintaining and inspecting the UAS to ensure that it is 

in a condition for safe operation 

12. 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. 

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

replacement, inspection, and life limit requirements for the aircraft and aircraft 

components. 

14. The UAS operated under this exemption must comply with all manufacturer safety 

bulletins. 

15. 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 Colombia, Puerto Rico, a territory, a possession, or the Federal 
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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. 

16. 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.

17. 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. 

18. The UAS 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. 

19. The UAS 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. 

20. If the UAS loses communications, or loses its GPS signal, the UAS must return to a 

predetermined location within the private, or controlled-access property. 

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

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

weather conditions) there is enough available power for the UAS 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. 

23. 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.
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24. 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. 

25. 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. 

26. The UAS must remain clear and give way to all manned aviation operations and 

activities at all times. 

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

28. 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 UAS 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 UAS, 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. 

29. The PIC, VO, operator trainees or essential persons are not considered 

nonparticipating persons under this exemption. 

30. 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.

31. 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. 
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**For the purpose of closed-set motion picture and television filming and production, the 

following additional conditions and limitations apply. 

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

as documented in this grant of exemption. 

33. 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: 

o Dates and times for all flights; 

o Name and phone number of the operator for the UAS aerial filming conducted 

under this grant of exemption; 

o Name and phone number of the person responsible for the on-scene operation of 

the UAS; 

o Make, model, and serial or N-Number of UAS to be used; 

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

o 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; 

o Signature of exemption holder or representative; and 

o A description of the flight activity, including maps or diagrams of any area, city, 

town, county, and/or state over which filming will be conducted and the altitudes 

essential to accomplish the operation. 

34. 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. 

STATUTORY CRITERIA PROVIDED IN SECTION 333 

The Federal Aviation Act (49 U.S.C.§ 44701 (f)) and Section 333 of the Reform Act both 

authorize the FAA to exempt aircraft from the requirement for an airworthiness 

certificate, upon consideration of the size, weight, speed, operational capability, and 

proximity to airports and populated areas of the particular UAS. In all cases, an analysis 

of these criteria demonstrates that the UAS operated without an airworthiness certificate 

and under the restrictions proposed will be at least as safe, or safer, than a conventional 

aircraft (fixed wing or rotorcraft) operating with an airworthiness certificate without the 

restrictions and conditions proposed. 

Since the UAS fully loaded weighs no more than 55 lbs. and is operated without an 

onboard pilot, there is no ability or place to carry certification and registration documents 
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or to display them on the unmanned aircraft. An equivalent level of safety will be 

achieved by keeping these documents at the ground control point where the pilot flying 

the UAS will have immediate access to them. Given the size of the unmanned aircraft, 

the FAA registration number will be displayed on the airframe in as large a font as 

possible. 

14 C.F.R. § 61.23(a) & (c): MEDICAL CERTIFICATES

Exemption #11221, #11284, and many others have provided that a U.S. driver’s license 

could be used in lieu of the medical certificate. 

14 C.F.R. § 61.101(e)(4) & (5): RECREATIONAL PILOT PRIVILEGES AND 

LIMITATIONS & 14 C.F.R. § 61.315(a): SPORT PILOT LIMITATIONS 

Exemption # 11221, # 11284, and many others have provided that the “PIC must hold 

either an airline transport, commercial, private, recreational, or sport pilot certificate.” 

Likewise, Ghost Tracs LLC is also performing commercial UAS work and is asking for 

the same restrictions, which have been previously deemed to provide an equivalent level 

of safety as the burdensome regulations. 

14 C.F.R. § 61.113 (a): PRIVATE PILOT PRIVILEGES AND LIMITATIONS: 

PILOT IN COMMAND. 

Sub-sections 61.113(a) limit private pilots to non-commercial operations. Because the 

UAS will not carry a pilot or passengers, the proposed operations can achieve the 

equivalent level of safety of current operations by requiring the PIC operating the aircraft 

to have a private pilot's license rather than a commercial pilot's license to operate this 

small UAS. Unlike a conventional aircraft that carries the pilot and passengers, the UAS 

is remotely controlled with no living thing on board. 

14 C.F.R. § 91.7(a): CIVIL AIRCRAFT AIRWORTHINESS. 

The DJI Inspire 1 uses the DJI A2 flight controller that has been previously approved in 

Exemption #11252. The DJI Inspire 1 aircraft configuration has been granted in other 

exemptions such as Exemption #11303 & #11279. Therefore, this aircraft should not be 

required to have an airworthiness certificate based upon the FAA’s previous 

determinations. 
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14 C.F.R. § 91.119: MINIMUM SAFE ALTITUDES 

Section 91.119 establishes safe altitudes for operation of civil aircraft. Section 91.119 (d) 

allows helicopters to be operated at less than the minimums prescribed, provided the 

person operating the helicopter complies with any route or altitudes prescribed for 

helicopters by the FAA. 

Because of the lack of flammable fuel, any risk associated with these operations is far 

less than those presently presented with conventional aircraft operating at or below 500 

AGL. In addition, the low-altitude operations of the UAS will ensure separation between 

these small UAS operations and the operations of conventional aircraft that must comply

with Section 91.119. 

14 C.F.R. § 91.121: ALTIMETER SETTINGS 

This regulation requires each person operating an aircraft to maintain cruising altitude by 

reference to an altimeter that is set "... to the elevation of the departure airport or an 

appropriate altimeter setting available before departure." As the UAS may not have a 

barometric altimeter, but instead a GPS altitude read out, an exemption may be needed. 

The operator, pursuant to the operating manuals, will achieve an equivalent level of 

safety.

14 C.F.R. § 91.151(a): FUEL REQUIREMENTS FOR FLIGHT IN VFR 

CONDITIONS 

Section 91.151 (a) prohibits an individual from beginning "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." 

Ghost Tracs LLC. believes that an equivalent level of safety can be achieved by 

restricting operations to “be completed within 30 minutes flight time or with 25% battery

power remaining, whichever occurs first.” (Exemption #11062, at page 27). If, however, 

the above limitations are not satisfactory to the Administrator, the petitioner is prepared, 

in the name of expediency, to accept limiting the PIC from beginning a UAS flight unless 

(considering wind and forecast weather conditions and assuming normal cruising speed) 

“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.” (Exemption #11284, page 5)
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14 C.F.R. § 91.405 (a); § 91.407 (a) (1); § 91.409 (a) (2); § 91.417(a) & (b): 

MAINTENANCE INSPECTIONS 

These regulations require than an aircraft operator or owner “shall have that aircraft 

inspected as prescribed in subpart E of this part and shall between required inspection, 

except as provided in paragraph (c) of this section, have discrepancies repaired as 

prescribed in part 43 of this chapter” and others shall inspect or maintain the aircraft in 

compliance with Part 43. Given that these sections and Part 43 apply to only aircraft with 

an airworthiness certificate, these sections will not apply to Ghost Tracs LLC. An 

equivalent level of safety will be achieved because this UAS is very limited in size, and 

will carry a small payload, and operate only in restricted areas for limited periods of time. 

Moreover, the operator is the person most familiar with the aircraft and best suited to 

maintain the aircraft in an airworthy condition to provide the equivalent level of safety. 

Lastly, Ghost Tracs LLC. will operate in accordance with the manufactures manual

which will provide an equivalent level of safety.

Other Exemptions

Petitioner requests relief from any other Federal Aviation Regulation that the FAA deems 

applicable to and preclusive of the proposed UAS Search & Rescue Operations in the 

absence of such an exemption.

Request for Blanket COA

Petitioner hereby requests a blanket, nationwide Certificate of Waiver or Authorization 

for airspace use within Class G airspace, at or below 400 feet. The need for a blanket 

COA for Petitioners proposed operation (or an exemption from the need to obtain one) is 

self-evident. Unlike other pre-planned small UAS operations, search and rescue requires 

an operational response on little notice, and minutes can literally make the difference 

between life and death. FMRA Section 333 directly contemplates that a certificate of 

waiver or authorization is not necessarily required for the operation of civil UAS. It 

provides that in making a Section 333 determination concerning operation of unmanned 

aircraft systems, “the Secretary shall determine . . . .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.” FMRA 

Section 333(b) By using the word “whether,” Congress specifically contemplated that a 

COA would not necessarily be required for any civil operation. Therefore, the FAA has 

the authority to either exempt Petitioner from the need to obtain a COA, or to issue to 

Ghost Tracs LLC. a standing blanket COA that is suited for the contemplated search and 

rescue operations. 
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Ghost Tracs LLC. respectfully submits that a standing COA granted for search and rescue 

operations is overwhelmingly in the public interest because it will enable life-saving 

operations to commence sooner, and reduce the administrative burden on the FAA itself. 

The FAA has recently indicated that holders of UAS exemptions under Section 333 are 

now granted a “blanket” COA for any operation up to 200 feet AGL. See March 20, 2015 

Memorandum from Elizabeth L. Ray to Terry Biggio, “Small Unmanned Aircraft 

Systems Operations in the National Airspace System.” However, this streamlined (or socalled “blanket”) COA apparently still requires the operator to issue a Notice to Airmen 

(NOTAM) “at least 24 hours prior to the proposed operation.” In many instances Ghost 

Tracs LLC. expects to be called upon with less than 24 hours’ notice. Ghost Tracs LLC.

requests that its blanket COA issued in connection with the requested exemption require 

only that Ghost Tracs LLC. issue a NOTAM “as far in advance of operations as 

practicable,” with no specific minimum notice provision. 

Additionally, Ghost Tracs :LLC. FSOP and equipment are optimized for search and 

rescue from an operational altitude of just below 400 feet AGL. The 200 feet AGL in the 

“blanket” COA is too low an altitude for these operations. Without a streamlined COA at 

an altitude higher than 200 feet, Ghost Tracs LLC. will be waiting days (or weeks) for a 

civil COA just to be able to operate at a modestly higher altitude, rendering the 

exemption potentially unworkable. Ghost Tracs LLC. requests a streamlined COA for the 

highest altitude the FAA will permit, ideally 400 feet AGL. 

An equivalent level of safety is established for these blanket COA parameters because, 

currently, operations of this kind are permitted by FAA, by recreational model aircraft 

operators without any COA or NOTAM requirements. Moreover, Ghost Tracs LLC.

operations are subject to NIMS protocols and coordination with Incident Command and 

other first responders, who will be aware of air traffic in the area. Therefore, unlike 

commercial UAS operations undertaken for industrial purposes, added layers of safety

exist. All of these factors support the issuance of a streamlined or “blanket” COA for 

Ghost Tracs LLC. in Class G airspace up to 400 feet above ground level, or a 

determination pursuant to FMRA Section 333(b) that a COA is not required for Ghost 

Tracs LLC. search and rescue operations.

Conclusion: 

The operation of Ghost Tracs LLC. using a small UAS, weighing less than 55 lbs., 

conducted under the proposed restrictions outlined above, will provide an equivalent 

level of safety supporting the grant of the exemptions requested herein. 
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A Summary That Can Be Published In The Federal Register:

Petitioner: Ghost Tracs LLC. seeks an exemption for the operation of unmanned aircraft 

systems (UAS) for purposes of aerial photography, videography, and search and rescue

operations. The benefit to the public interest of such an exemption is unquestionable. The 

use of manned aircraft is in many instances much more expensive, and much more 

dangerous, than the operations proposed herein. Thus, the operations are of enormous 

public benefit. 

Regulations from which the exemption is requested: 

o 14 C.F.R. § 61.23(a) 

o 14 C.F.R. § 61.101

o 14 C.F.R. § 61.113(a)

o 14 C.F.R. § 61.315

o 14 C.F.R. § 91.7(a)

o 14 C.F.R. § 91.119

o 14 C.F.R. § 91.121

o 14 C.F.R. § 91.151(a)(1)

o 14 C.F.R. § 91.405(a)

o 14 C.F.R. § 91.407(a)(1)

o 14 C.F.R. § 91.409(a)(1) & (2)

o 14 C.F.R. § 91.417(a) & (b)

Based upon the foregoing, Ghost Tracs LLC. requests that the FAA grant it the necessary

exemptions under Section 333 of the FAA Reform ACT and 49 U.S.C. §44701(f) of the 

Federal Aviation Act as requested herein to allow commercial operations of the DJI 

Inspire 1 within the continental United States and its territories. 

Respectfully Submitted,

Jason Thomas McGarraugh

Ghost Tracs Ventures LLC

1916 Trammel Drive 

Nolensville TN. 37135

Phone: 615-719-2972

Fax: 561-427-7255

Email: Jason@GhostTracs.com