UNITED STATES OF AMERICA 

DEPARTMENT OF TRANSPORTATION 

FEDERAL AVIATION ADMINISTRATION 

WASHINGTON, DC 

Regulatory Docket No. 

IN THE MATTER OF THE PETITION FOR EXEMPTION OF:

Air-Reelz LLC

FOR AN EXEMPTION SEEKING RELIEF FROM THE REQUIREMENTS OF 

TITLE 14 OF THE CODE OF FEDERAL REGULATIONS

SECTIONS 61.101(e)(4) & (5), 61.113(a) & (b), 61.23(a), 61.315(a), 91.7(a), 

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

(b) CONCERNING COMMERCIAL OPERATION OF DJI INSPIRE 1 

UNMANNED AIRCRAFT SYSTEMS

PURSUANT TO SECTION 333 OF

THE FAA MODERNIZATION AND REFORM ACT OF 2012

(PUBLIC LAW 112-95)

 Submitted on June 23rd, 2015 

Christopher Earle-Handley 

Air-Reelz LLC 

22 Country Club Drive Apt 29 

Manchester, NH 03102 

Tel: (978) 347-5964 

Email: info@air-reelz.com
2

TABLE OF CONTENTS

Page 

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

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

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

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

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

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

THE SPECIFIC SECTIONS OF 14 C.F.R. FROM WHICH AIR-REELZ LLC SEEKS 

EXEMPTION ........................................................................................................................8 

THE EXTENT OF RELIEF AIR-REELZ LLC SEEKS AND THE REASON AIR-REELZ 

LLC SEEKS THE RELIEF..........................................................................11 

THE REASONS WHY GRANTING AIR-REELZ LLC’S REQUEST WOULD BE IN 

THE PUBLIC INTEREST ........................................................................... 15 

THE REASONS WHY GRANTING THE EXEMPTION WOULD NOT 

ADVERSELY AFFECT SAFETY ...................................................................................19 

SUMMARY THAT CAN BE PUBLISHED IN THE FEDERAL REGISTER. ............34 

ADDITIONAL INFORMATION, VIEWS, OR ARGUMENTS AVAILABLE TO 

SUPPORT AIR-REELZ LLC’S REQUEST...................................................................... 34 

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

APPENDICES........................................................................................37 
3

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 
4

SUMMARY

Christopher Earle-Handley seeks exemption from the requirements of 14 C.F.R §§ 

61.101(e)(4) and (5), 61.315(a), 61.23(a), 91.7(a), 91.121, 91.151(b), 91.405(a), 

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

System pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 

(FMRA). This exemption will permit Air-Reelz LLC to operate an Unmanned Aircraft 

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

areas including but not limited to: construction sites, building inspections, agricultural 

lands, wineries, outdoor recreational facilities, real estate, special events, businesses and 

landscapes within the United States. 

INTRODUCTION AND INTERESTS OF THE PETITIONER

Air-Reelz LLC will provide its clients with the highest quality digital content for 

use in their commercial, personal, and non-profit multimedia projects. Air-Reelz LLC will 

bring together years of professional marketing expertise, award-winning production talent 

and state-of-the-art technology to make studio quality productions within reach for 

organizations of any size. Air-Reelz LLC will also leverage years of professional civil 

engineering experience to become a leading provider of geomapping and image analysis 

services to the civil engineering and environmental monitoring industries. Air-Reelz LLC 

has over 2 years recreational/hobby experience in all aspects of aerial video and 

photography. The objective of Air-Reelz LLC aerial video and photography operations is 

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

specifically targeting: 

• Aerial event filming and photography 

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

• Agricultural surveys and environmental monitoring 

• Civil engineering inspection and documentation 
5

BACKGROUND

Unmanned Aircraft Systems: DJI Inspire 1 UAS

Air-Reelz LLC seeks an exemption to operate DJI systems for compensation or 

hire within the NAS. The DJI Inspire 1 (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 Inspire 1 is an electric powered rotary wing 

UAS that is capable of transmitting live airborne video images and location information to 

a Ground Control Station (GCS). The Inspire stores the photographs and data on board 

and makes them available for download after completion of the flight. The Inspire is 22 in 

x 22 in x 8 in and weighs 6.4 pounds, well under the 55 lbs mandated in the FMRA. The 

Inspire can conduct hovering flight and has a maximum cruising speed of 42 knots. It is 

battery powered, has a flight endurance of 22 minutes and can operate in temperatures 

ranging from 0° to 40° C. The Inspire’s omni-directional antenna has a range of 2.1 km 

and operates in the 2.420 – 2.483 GHz frequency range. 

The Inspire 1 that will be operated by Air-Reelz LLC will be registered in 

accordance with 49 U.S.C. 44103, Registration of Aircraft, as well as 14 

C.F.R Part 47, Aircraft Registration, and marked in accordance with 14 C.F.R. Part 45, 

Identification and Registration Marking. 

BASIS FOR PETITION

Petitioner, Air-Reelz LLC, 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 in the National
6

Airspace System (NAS), and for an exemption from the requirements of 14 C.F.R §§ 

61.101(e)(4) and (5), 61.315(a), 61.23(a), 91.7(a), 91.121, 91.151(b), 91.405(a), 

91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b). 

In consideration of the speed, weight, size, and limited operating area associated 

with the unmanned aircraft and its operation, Air-Reelz’s 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, Air-Reelz LLC 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. 

Air-Reelz LLC submits that the requested relief is proper since an equivalent level 

of safety will be ensured. Air-Reelz LLC 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, Air-Reelz LLC will 

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

Relief from certain requirements of Section 61.101(e)(4) and (5) entitled 

Recreational pilot privileges and limitations: Pilot in command, and from Section 

61.315(a) entitled What are the privileges and limits of my sport pilot certificate, and from 

Section 61.23(a) entitled Medical certificates: Requirements and duration, is requested by 

Air-Reelz LLC to the extent necessary to allow a Pilot in Command (PIC) holding a sport 

pilot or higher level certificate, as well as a valid driver’s license, and who has 

demonstrated, by meeting minimum flight- hour and currency requirements, that the 
7

PIC is able to safely operate the DJI Inspire 1 UAS in a manner consistent with this 

exemption, including evasive and emergency maneuvers and maintaining appropriate 

distances from people, vessels, vehicles and structures. 

Air-Reelz LLC seeks relief from Section 91.7(a), entitled Civil aircraft 

airworthiness, because the DJI Inspire 1 UAS does not require an airworthiness certificate 

in accordance with 14 C.F.R. Part 21, Subpart H. As such, Air-Reelz LLC submits that it 

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

determining that the UASs is in compliance with the operating documents (i.e., Monthly 

Maintenance Log, and DJI Inspire 1 Instruction Manual), and that the aircraft are in a 

condition for safe flight. 

Air-Reelz LLC also seeks an exemption from the requirements of Section 91.121, 

entitled Altimeter Settings, as the DJI Inspire 1 UA will not have a typical barometric 

altimeter onboard. However, altitude information of the DJI Inspire 1 UA 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 Air-Reelz LLC’s operation of the DJI 

Inspire 1 UAS within visual line of sight, at or below 400 feet AGL, will ensure a level of 

safety equivalent to Section 91.121. 

Additionally, Air-Reelz LLC seeks an exemption from the requirements of Section 

91.151(b), entitled Fuel requirements for flight in VFR conditions. Air-Reelz LLC submits 

that safety will not be affected by operation of the 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 approximately 13.5 minutes to the first point of 
8

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, Air-Reelz 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: 

Christopher Earle-Handley 

Air-Reelz LLC 

22 Country Club Drive 

Apt 29

Manchester, NH 03102 

Tel: (978) 347-5964 

Email: info@air-reelz.com

B. The Specific Sections Of 14 C.F.R. From Which Air-Reelz LLC Seeks 

Exemption.

1. Air-Reelz LLC Seeks Exemption From The Requirements Of Section 

61.101(e)(4) and (5).

Section 61.101, entitled Recreational pilot privileges and limitations: Pilot in 

command, subsection (e)(4) and (5) prescribe the following, in relevant part: 

(e) Except as provided in paragraphs (d) and (i) of this section, a recreational pilot 

may not act as pilot in command of an aircraft--

(4) For compensation or hire; 

(5) In furtherance of a business; 

2. Air-Reelz LLC Seeks Exemption From The Requirements Of Section 

61.23(a).
9

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

and duration, subsection (a) prescribe the following, in relevant part: 

(f) Except as provided in paragraphs (d) and (i) of this section, a recreational pilot 

may not act as pilot in command of an aircraft--

3. Air-Reelz LLC Seeks Exemption From The Requirements Of Section 

61.315(a).

Section 61.315(a), entitled What are the privileges and limits of my sport pilot 

certificate, subsection (a) prescribe the following, in relevant part: 

(c) You may not act as pilot in command of a light-sport aircraft: 

(2) For compensation or hire. 

(3) In furtherance of a business.--

4. Air-Reelz LLC Seeks Exemption From The Requirements Of Section 

91.7(a).

Section 91.7, entitled Civil aircraft airworthiness, subsection (a), states the 

following: 

(a) No person may operate a civil aircraft unless it is in an airworthy condition. 

5. Air-Reelz LLC 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--
10

(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. 

 

6. Air-Reelz LLC 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.

7. Air-Reelz LLC Seeks Exemption From The Requirement Of Section 

91.405(a).

Section 91.405, entitled Maintenance required, subsection (a), states the following: 

Each owner or operator of an aircraft—

(a) Shall have that aircraft inspected as prescribed in subpart E of this part and shall 

between required inspections, except as provided in paragraph (c) of this section, 

have discrepancies repaired as prescribed in part 43 of this chapter[.] 

8. Air-Reelz LLC 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[.] 
11

9. Air-Reelz LLC 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. 

10. Air-Reelz LLC 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. 
12

(iii) The time since last overhaul of all items installed on the aircraft which 

are required to be overhauled on a specified time basis. 

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

last inspection required by the inspection program under which the 

aircraft and its appliances are maintained. 

(v) The current status of applicable airworthiness directives (AD) and 

safety directives including, for each, the method of compliance, the AD 

or safety directive number and revision date. If the AD or safety 

directive involves recurring action, the time and date when the next 

action is required. 

(vi) Copies of the forms prescribed by § 43.9(d) of this chapter for each 

major alteration to the airframe and currently installed engines, rotors, 

propellers, and appliances. 

(b) The owner or operator shall retain the following records for the periods 

prescribed: 

(1) The records specified in paragraph (a)(1) of this section shall be retained 

until the work is repeated or superseded by other work or for 1 year after the 

work is performed. 

(2) The records specified in paragraph (a)(2) of this section shall be retained 

and transferred with the aircraft at the time the aircraft is sold. 

(3) A list of defects furnished to a registered owner or operator under § 43.11 of 

this chapter shall be retained until the defects are repaired and the aircraft is 

approved for return to service. 

C.The Extent Of Relief Air-Reelz LLC Seeks And The Reason Air-Reelz LLC 

Seeks The Relief.

1. Extent Of Relief Air-Reelz LLC Seeks And The Reason Air-Reelz LLC 

Seeks Relief From Section 61.113(a) and 

(b).

Relief from Section 61.113(a) and (b) entitled Private pilot privileges and 

limitations: Pilot in command, is requested to the extent necessary to allow a PIC holding a 

private pilot or higher level certificate, as well as a current and valid airman medical 
13

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

proposed UAS flight operations for compensation or hire. 

This relief is requested since the limitations set forth in Section 61.113(a) and (b) 

state that a private pilot may, for compensation or hire, act as PIC of an aircraft in 

connection with any business or employment if: (1) The flight is only incidental to that 

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

compensation or hire. 

As set forth more fully below, Air-Reelz LLC submits that an equivalent level of 

safety will be maintained because no PIC will be allowed to operate the DJI Inspire 

1 UAS UA unless that PIC has met certain flight-hour and currency requirements, 

demonstrating that the PIC is able to safely operate either the DJI Inspire 1 UAS in a 

manner consistent with the operations specifications as described in this exemption, 

including evasive and emergency maneuvers, as well as maintaining appropriate distances 

from people, vessels, vehicles and structures. 

Further, Air-Reelz LLC submits that all flights of the DJI Inspire 1 UAS, conducted 

by the PIC pursuant to the grant of this Petition: (1) will be incidental to Air-Reelz LLC 

business; and (2) will not carry passengers or property for compensation or hire. 

2.Extent Of Relief Air-Reelz LLC Seeks And The Reason Air-Reelz LLC 

Seeks Relief From Section 61.23(a). 

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

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

holding a sport pilot certificate or higher level certificate, as well as a current and valid 

driver’s license, to conduct the proposed UAS flight operations for compensation or hire. 

This relief is requested since the limitations set forth in Section 61.23(a) otherwise 

require the PIC of any flight for compensation or hire to hold a comprehensive FAA issued 
14

medical certificate. In Exemption No. 11213 to Aeryon Labs, Inc., the FAA “finds that, 

because of the risk mitigations established in the conditions and limitations of this 

exemption, a person that holds a U.S. issued driver’s license who is operating a UAS will 

not adversely affect safety. The FAA is granting relief from § 61.23(a) to allow any pilot 

that holds one of the pilot’s certificates discussed above to operate a UAS under this 

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

The FAA is also granting relief from § 61.23(c) to allow sport pilot certificate holders to 

operate aircraft other than LSA with a U.S. issued driver’s license under this exemption.” 

3.Extent Of Relief Air-Reelz LLC Seeks And The Reason Air-Reelz LLC 

Seeks Relief From Section 61.315(a). 

Relief from Section 61.315(a) entitled What are the privileges and limits of my 

sport pilot certificate, is requested to the extent necessary to allow a PIC holding a sport 

pilot or higher level certificate to conduct the proposed UAS flight operations for 

compensation or hire. 

This relief is requested since the limitations set forth in Section 61.315(a) restrict a 

sport pilot from acting as the PIC of any flight for compensation or hire, or for the 

furtherance of any business. 

In Exemption No. 11213 to Aeryon Labs, Inc., the FAA re-assessed the level of 

pilot certificate that would be appropriate for the petitioner’s operations. In evaluating this 

petition, similar to the evaluation of the private and commercial pilot certificates in 

Exemption No. 11062, the agency compared the aeronautical knowledge requirements of 

the recreational and sport pilot certificates to those of the private pilot certificate. They 

found that the aeronautical knowledge requirements that would be applicable to a UAS 

operation for a recreational pilot and sport pilot certificate are substantially similar as those 

for a private pilot certificate. 
15

Additionally, similar to the private and commercial pilot certificates, holders of 

recreational and sport pilot certificates are subject to security screening by the Department 

of Homeland Security (DHS). 

Therefore, because they must demonstrate aeronautical knowledge relevant to UAS 

operations and are subject to DHS screening, factors that were considered by the FAA in 

allowing private pilot operations under previous exemptions, the FAA now determines that 

holders of recreational and sport pilot certificates may serve as the PIC for UAS 

operations. 

4.Extent Of Relief Air-Reelz LLC Seeks And The Air-Reelz LLC 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 Air-Reelz LLC to determine that the DJI Inspire 1 UAS are in 

airworthy condition prior to every flight by ensuring that the UAS is in compliance with 

the operating documents (i.e., the DJI Inspire 1 Maintenance Manual, Monthly 

Maintenance Log, and DJI Inspire 1 Instruction Manual). 

Air-Reelz LLC seeks the requested relief because the DJI Inspire 1 UAS do not 

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

Therefore, Air-Reelz LLC will ensure that the DJI Inspire 1 UAS are in airworthy 

condition based upon its compliance with the operating documents (i.e., Monthly 

Maintenance Log, and DJI Inspire 1 Instruction Manual) prior to every flight, and further, 

determine that the aircraft are in condition for safe flight, as stated in the conditions and 

limitations below. 

5.Extent Of Relief Air-Reelz LLC Seeks And The Reason Air-Reelz LLC 

Seeks Relief From Section 91.121. 

Relief from Section 91.121, entitled Altimeter settings, may be required to allow 

flight operations of the DJI Inspire 1 UAS, which utilize a barometric pressure sensor, GPS 
16

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), Air-Reelz LLC 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 UAs are equipped with a barometric pressure sensor 

and GPS equipment, which automatically ensures that a ground level pressure setting will 

be established prior to each flight, and provides the PIC with altitude information of the 

UA on the heads-up display of the GCS. 

6.Extent Of Relief Air-Reelz LLC Seeks And The Air-Reelz LLC 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 UAs 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 that for at least 4.5 minutes. 

Air-Reelz LLC 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 Air-Reelz

proposes to conduct pursuant to this Petition. 
17

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

UAS, the DJI Inspire 1 operating documents, and Air-Reelz LLC’s proposed operating 

limitations, ensure that Air-Reelz LLC will safely operate the battery powered DJI Inspire 

1 UAs during daylight hours in visual meteorological conditions (VMC), under visual 

flight rules (VFR), with enough battery power to fly for a total duration of 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. 

7.Extent Of Relief Air-Reelz LLC Seeks And The Reason Air-Reelz LLC 

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, Air-Reelz LLC 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, AirReelz LLC will use trained technicians to perform maintenance, alterations, or preventive 

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

UAS operating documents (i.e., the DJI Inspire 1 Maintenance Manual, Monthly 

Maintenance Log, and DJI Inspire 1 Instruction Manual). Furthermore, Air-Reelz will 

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

D.The Reasons Why Granting Air-Reelz LLC 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 Air-Reelz 

LLC to safely, efficiently, and economically conduct aerial video and photography of 

construction sites, building inspections, agricultural lands, wineries, outdoor recreational 

facilities, real estate, special events, and landscapes over certain areas of the United States. 
18

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 

Air-Reelz LLC’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 UAS are battery powered and serve as a safe, efficient, and 

economical alternative to the manned aircraft traditionally utilized to obtain aerial imagery. 

By reducing the amount of manned aircraft needed to perform aerial acquisitions, an 

exemption allowing the use of a DJI Inspire 1 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 UAS do not require an airport to takeoff or land. Likewise, a reduction of 

manned aircraft conducting aerial video and photography missions would result in fewer 

aircraft that must be handled by air traffic control during the ground, takeoff, departure, 

arrival, and landing phases of flight operations. 

2. The Public Will Benefit From The Safety And Efficiency Of The DJI 

Inspire 1 UAS.

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 produce no air 

pollution, and is the most viable environmentally conscious alternative to the cabin class, 

six cylinder internal combustion engine aircraft that are typically utilized for aerial video 
19

and photography, while burning approximately 20-30 gallons per hour of leaded aviation 

fuel. The DJI Inspire 1 UAS, while reducing the carbon footprint of aerial acquisitions, 

also eliminates noise pollution, as the UASs are propelled by battery powered electric 

motors, rather than an internal combustion engine. 

By using the DJI Inspire 1 UAS to perform aerial acquisitions, the substantial risk 

to life and property in the air and on the ground, which is usually associated with 

traditional manned aircraft flight operations, will be substantially reduced or completely 

eliminated. Aside from the lack of flight crew members located onboard the aircraft, the 

DJI Inspire 1 UAS (weighing approximately 6.5 pounds maximum gross weights with a 

length of 17.3 inches, width of 17.7 inches, and with no fuel on board), 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, 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 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 Air-Reelz LLC, 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 
20

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 Air-Reelz LLC, 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, Air-Reelz LLC 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 the conditions set forth in any exemption granted under this petition. 

E. The Reasons Why Granting The Exemption Would Not Adversely Affect Safety, 

Or How The Exemption Would Provide A Level Of Safety At Least Equal To That 

Provided By The Rule From Which Air-Reelz LLC Seeks Exemption.

1. Reasons Why The 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, Air-Reelz LLC operation of the DJI Inspire 1 

UAS meet the conditions of FMRA Section 333, and will not require an airworthiness 

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

Section 333 provides authority for a UAS to operate without airworthiness 

certification and sets forth requirements for considering whether a UAS will create a 
21

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, Air-Reelz LLC 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 UAS Demonstrate Its Safe 

Characteristics.

The DJI Inspire 1 UAS does 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. 
22

i. Technical Specifications Of The DJI Inspire 1 UAS.

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

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

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

Enable The UAS 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 in the DJI Inspire 1 User Manual, attached hereto as Exhibit B. 

iii. The DJI Inspire 1 UAS Are Designed For Automatic Return To 

Home Point Or Hover In The Event Of Loss Of The Control Link 

Or Navigation.

When the Control Link is lost, the DJI Inspire 1 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 UAS are set 

forth in the DJI Inspire 1 User Manual, attached hereto as 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 in the DJI Inspire 1 User Manual. DJI Inspire 1 

User Manual is attached hereto as Exhibit B. 

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

Sight Of A Certificated Pilot in Command With A Safety Observer.
23

Air-Reelz LLC 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, proposes to commercially operate 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: 

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 

System. 

Proposed operations of any other aircraft will require a new petition or a petition 

to amend this grant. 

2. UAS operations under this exemption will be limited to conducting operations 

for the purpose of aerial video and photography. 

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

4. The UA must be operated at an altitude of no more than 500 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 
24

designation for the duration of the flight. The PIC must ensure that the SO can 

perform the functions prescribed in the operating documents. 

8. The SO must not perform any other duties beyond assisting the PIC with seeing 

and avoiding other air traffic and other ground based obstacles/obstructions and

is not permitted to operate the camera or other instruments. 

9. The operating documents and the grant of exemption must be accessible during 

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

discrepancy exists between the conditions and limitations contained in the grant 

of exemption and the procedures outlined in the operating documents, the 

conditions and limitations contained in the grant of exemption take precedence 

and must be followed. Otherwise, the operator must follow the procedures as 

outlined in its operating documents. The operator may update or revise its 

operating documents. It is the operator’s responsibility to track such revisions 

and present updated and revised documents to the Administrator upon request. 

The operator must also present updated and revised documents if it petitions for 

extension or amendment to the grant of exemption. If the operator determines 

that any update or revision would affect the basis upon which the FAA granted 

the exemption, then the operator must petition for amendment to its grant of 

exemption. The FAA’s UAS Integration Office (AFS-80) may be contacted if 

questions arise regarding updates or revisions to the operating documents. 

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

condition for safe flight. If the inspection reveals a condition that affects the 

safe operation of the UAS, the aircraft is prohibited from operating until the 

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

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

preflight inspection. All maintenance and alterations must be properly 

documented in the aircraft records. 

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

operation or flight characteristics, e.g. replacement of a flight critical 

component, must undergo a functional test flight. The PIC who conducts the 

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

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

inoperable components, items, or equipment, not already covered in the relevant 

sections of the operating documents. 

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

maintenance, overhaul, replacement, inspection, and life limit requirements. 

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

requirements, in accordance with the operating documents. Maintenance, 

inspection, alterations, and status of replacement/overhaul component parts must 
25

be noted in the aircraft records, including total time in service, description of 

work accomplished, and the signature of the authorized person returning the 

UAS to service. 

15. Each UASs operated under this exemption must comply with all manufacturer 

Safety Bulletins. 

16. The authorized person must make an entry in the aircraft record of the corrective 

action taken against discrepancies discovered between inspections. 

17. The PIC must possess at least a private pilot certificate and at least a current 

third- class medical certificate. 

18. The operator may not permit any PIC to operate unless the PIC meets the 

operator’s qualification criteria and demonstrates the ability to safely operate the 

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

exemption, including evasive and emergency maneuvers and maintaining 

appropriate distances from persons, vessels, vehicles and structures. PIC 

qualification flight hours must be logged in a manner consistent with 14 C.F.R. § 

61.51(b). Flights for the purposes of training the operator’s PICs are permitted 

under the terms of the exemption. However, training operations may only be 

conducted during dedicated training sessions. During training, proficiency, and 

experience-building flights, all persons not essential for flight operations are 

considered nonparticipants, and the PIC must operate the UA with appropriate 

distance from nonparticipants in accordance with 14 C.F.R. § 91.119. 

19. UAS operations may not be conducted during night, as defined in 14 C.F.R. § 

19.1. All operations must be conducted under visual meteorological 

conditions (VMC). If flight at night is required, a special request will be made at 

the FAA office closest to proposed area of operations. Flights under special 

visual flight rules (SVFR) are not authorized. 

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

denoted on a current FAA-published aeronautical chart unless a letter of 

agreement with that airport’s management is obtained, and the operation is 

conducted in accordance with a NOTAM as required by the operator’s COA. 

The letter of agreement with the airport management must be made available to 

the Administrator upon request. 

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

horizontally from a cloud or when visibility is less than 3 statute miles from the 

PIC. 
26

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 
27

operator must ensure that nonparticipating persons remain under such 

protection. If a situation arises where nonparticipating persons leave such 

protection and are within 500 feet of the UA, flight operations must cease 

immediately and/or; 

b. The aircraft is operated near vessels, vehicles or structures where the 

owner/controller of such vessels, vehicles or structures has granted 

permission and the PIC has made a safety assessment of the risk of 

operating closer to those objects and determined that it does not present 

an undue hazard, and; 

c. Operations nearer to the PIC, SO, operator trainees or essential persons 

do not present an undue hazard to those persons per § 91.119(a). 

32. All operations shall be conducted over private or controlled-access property 

with permission from the land owner/controller or authorized representative. 

Permission from land owner/controller or authorized representative will be 

obtained for each flight to be conducted. 

33. Any incident, accident, or flight operation that transgresses the lateral or 

vertical boundaries of the operational area as defined by the applicable COA 

must be reported to the FAA's UAS Integration Office (AFS-80) within 24 

hours. Accidents must be reported to the National Transportation Safety Board 

(NTSB) per instructions contained on the NTSB Web site: www.ntsb.gov.

2. Reasons Why An Exemption From The Requirements Of Section 61.113(a) 

And (b) Would Not Adversely Affect Safety.

Air-Reelz LLC submits that the equivalent level of safety established by 

Section 61.113(a) and (b) will be maintained because no PIC will be allowed to operate the 

DJI Inspire 1 UAS unless that PIC has demonstrated, by meeting minimum flight-hour and 

currency requirements, that the PIC is able to safely operate the DJI Inspire 1 UAS in a 

manner consistent with the exemption, including evasive and emergency maneuvers and 

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

Considering Air-Reelz LLC proposed area of operations, and the operating 

limitations set forth-above; the parallel nature of sport pilot aeronautical knowledge 

requirements to those of commercial pilot requirements (See Exemption No. 
28

11062); and the airmanship skills necessary to safely operate the DJI Inspire 1 UAS, AirReelz LLC submits that the additional manned airmanship experience of a commercially 

certificated pilot would not correlate to the airmanship skills necessary for Air-Reelz LLC 

specific proposed flight operations. 

The FAA has previously granted relief from Section 61.113(a) and (b) specific to 

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

Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112, 

11136, 11138, 11150, 11153, 11156, 11158, 11159, 11160, 11161). 

Air-Reelz LLC will not allow any PIC to operate the DJI Inspire 1 UAS unless that 

PIC has demonstrated, by meeting minimum flight-hour requirements or the DJI Inspire 1 

UAS training and currency requirements, that the PIC is able to safely operate the DJI 

Inspire 1 UAS in a manner consistent with this exemption, including evasive and 

emergency maneuvers and maintaining appropriate distances from people, vessels, 

vehicles and structures. 

Specifically, the PIC must have accumulated and logged, in a manner consistent 

with 14 C.F.R. § 61.51(b), 25 hours of total time as a UAS rotorcraft pilot (with a 

minimum of 5 hours of those hours as a UAS pilot operating the same make and model of 

UAS to be used for operations under the exemption). In addition to the hour requirements, 

the PIC must accomplish 3 takeoffs and landings in the preceding 90 days (for currency 

purposes). 

As in Exemption Nos. 11062, 11138, and 11153, prior documented flight 

experience that was obtained in compliance with applicable regulations will ensure an 

equivalent level of safety during Air-Reelz LLC proposed operations. The Administrator 

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

applicable regulations would ensure safe operations, stating as follows: 
29

In Exemption No. 11062, the FAA required that prior to conducting operations for 

the purpose of motion picture filming (or similar operations), the PIC must have 

accumulated and logged, in a manner consistent with 14 CFR 61.51(b), 25 hours of 

total time as a UAS rotorcraft pilot including at least 10 hours logged as a UAS 

pilot with a multi-rotor UAS. Prior to operations under Exemption No. 11062, the 

PIC must also have accumulated and logged a minimum of 5 hours as a UAS pilot 

operating the same make and model of UAS to be used for operations under the 

exemption. For clarification, the FAA considers these minimum hour requirements 

to be inclusive rather than additive; i.e. 5 hours make and model time may be 

included in the 10 hours of multi-rotor time and the 10 hours may be included in 

the total 25 hours of UAS rotorcraft time. In addition to the hour requirements, the 

PIC must accomplish 3 takeoffs and landings in the preceding 90 days (for 

currency purposes). The FAA finds that at a minimum, the flight-hour 

requirements in Exemption No. 11062 are appropriate to practice and build 

proficiency in the skills necessary to safely conduct the petitioner’s proposed 

operations. The FAA also finds that prior documented flight experience that was 

obtained in compliance with applicable regulations would satisfy this requirement. 

Training, proficiency, and experience-building flights can also be conducted under 

the grant of exemption to accomplish the required flight time. During training, 

proficiency, and experience-building flights the PIC is required to operate the UA 

with appropriate distances in accordance with 14 C.F.R 91.119. 

Exemption No. 11138 at page 15. 

Accordingly, Air-Reelz will ensure safe operations by not allowing any PIC to 

operate the DJI Inspire 1 UAS unless that PIC has demonstrated, by meeting minimum 

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

1 UAS in a manner consistent with the exemption, including evasive and emergency 

maneuvers and maintaining appropriate distances from people, vessels, vehicles and 

structures. 

3. Reasons Why An Exemption From The Requirements Of Section 91.7(a) 

Would Not Adversely Affect Safety.

The equivalent level of safety established by Section 91.7(a) will be maintained 

because prior to every flight, Air-Reelz LLC 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. 
30

Additionally, the FAA has previously granted relief from Section 91.7(a) specific to 

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

Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112, 

11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161). 

4. Reasons Why An Exemption From The Requirements Of Section 91.121 

Would Not Adversely Affect Safety.

The equivalent level of safety established by Section 91.121 will be maintained 

because the altitude information of the DJI Inspire 1 UAS will be provided to the PIC via 

GPS equipment and a radio communications telemetry data link, which downlinks from 

the UAS to the GCS for active monitoring of the flight path and altitude. This altitude 

information, combined with Air-Reelz LLC’s 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. The altitude information will be generated by GPS equipment installed 

onboard the aircraft. Prior to each flight, a zero altitude initiation point is automatically 

established by the UASs at ground level. 

The FAA has previously granted relief from Section 91.121 specific to UAS, in 

circumstances similar, in all material respects, to those presented herein (e.g. Exemption 

Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11112, 11136, 11138, 

11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161). 

5. Reasons Why An Exemption From The Requirements Of Section 91.151(b) 

Would Not Adversely Affect Safety.

A grant of this exemption would ensure an equivalent level of safety established by 

14 C.F.R. Section 91.151(b) as a result of (1) the technical specifications of the DJI Inspire 

1 UAs; (2) the limitations on the proposed flight operations; and (3) the location of the 

proposed flight operations. Accordingly, Air-Reelz will ensure that it will safely operate 
31

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 provide audible 

and visual warnings to the PIC at the GCS when the UAs experiences low battery voltage, 

the first warning occurring at approximately 33% 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). 

6. Reasons Why An Exemption From The Requirements Of Sections 

91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), And 91.417(a) & (b) Would 

Not Adversely Affect Safety.
32

In seeking this exemption, Air-Reelz LLC 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 Air-Reelz LLC will use trained technicians to perform maintenance, alterations, or 

preventive maintenance on the UAS using the methods, techniques, and practices 

prescribed in the operating documents (i.e., the DJI Inspire 1 

Maintenance Manual, Monthly Maintenance Log, and DJI Inspire 1 Instruction Manual). 

Furthermore, Air-Reelz LLC 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, Air-Reelz LLC will maintain the equivalent level of safety established by 

Sections 91.405(a), 91.409(a)(1), and 91.409(a)(2). A copy of the DJI 

Inspire 1 User Manuals are attached hereto as Exhibit B; a copy of the DJI Inspire 1 

Maintenance Manual is attached hereto as Exhibit C; a copy of the DJI Inspire 1 UAS 

Maintenance LOG is attached hereto as Exhibit D. 

Likewise, the exemption sought will not adversely affect safety because Air-Reelz 

LLC 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. 
33

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 Air-Reelz LLC proposed operating limitations, the operating 

documents, and the technical aspects of the DJI Inspire 1 UAS, Air-Reelz LLC submits 

that safety will not be adversely affected by granting exemption from 

14 C.F.R. Sections 91.405(a), 91.407(a)(1) and (a)(2), 91.409(a)(2), and 91.417(a) and (b). 

The FAA has previously granted relief specific to UAS in circumstances similar, in all 

material respects, to those presented herein (e.g. Exemption Nos. 11062, 11063, 11064, 

11065, 11066, 11067, 11080, 11109, 11110, 11112, 11136, 11138, 11150, 

11153, 11156, 11157, 11158, 11159, 11160, 11161). 

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

In accordance with Section 333 of the FAA Modernization and Reform Act of 

2012 (FMRA) and 14 C.F.R. § 21.16 entitled Special Conditions, Air-Reelz LLC 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 §§ 61.113(a) & (b), 91.7 (a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 

91.409(a)(1) & (a)(2), and 91.417(a) & (b). Such special conditions will permit safe 

operation of the UAs for the limited purpose of conducting aerial video and photography 

over certain areas of the United States for compensation or hire. FMRA Section 333 sets 

forth the requirements for considering whether a UAS will create a hazard to users of the 
34

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 

FAA finds necessary to establish a level of safety equivalent to that established in 

the regulations. 

See 14 C.F.R. § 21.16. 

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

may prescribe special conditions for Leading Edge’s intended operation of the DJI Inspire 

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 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 

91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b). 

F. A Summary That Can Be Published In The Federal Register, stating: The Rules 

From Which Air-Reelz LLC Seeks Exemption:

Air-Reelz LLC seeks exemption from the requirements of 14 C.F.R Sections 

61.101(e)(4) and (5), 61.315(a), 61.23(a), 91.7(a), 91.121, 91.151(b), 

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

A Brief Description Of The Nature Of The Exemption Air-Reelz LLC Seeks:
35

This exemption will permit Air-Reelz LLC 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 AirReelz LLC 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, Air-Reelz LLC 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, Air-Reelz LLC 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. 

CONCLUSION

As set forth herein, Air-Reelz LLC 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 Air-
36

Reelz LLC 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, Air-Reelz LLC respectfully 

requests that the Administrator grant this Petition for an exemption from the requirements 

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

91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b), and permit Air-Reelz 

LLC to operate the DJI Inspire 1 UAS commercially for the purpose of conducting aerial 

video and photography over areas of the United States. 

Dated: June 23rd, 2015 

Respectfully submitted, 

Christopher Earle-Handley 

Christopher Earle-Handley

Air-Reelz LLC

22 Country Club Drive Apt 29

Manchester, NH 03102

Tel: (978) 347-5964

Email: info@air-reelz.com

Exhibits:

A – DJI Inspire 1 Specifications Data Sheet 

B – DJI Inspire 1 Manufacturer’s User Manual

C – DJI Inspire 1 Maintenance Manual 

D – Monthly Maintenance Log 
37

EXHIBIT – A 

DJI Inspire 1 Specifications Data Sheet 
38

Aircraft Model

T600 

Weight (Battery Included)

2935 g 

Hovering Accuracy (GPS Mode)

Vertical: 0.5 m 

Horizontal: 2.5 m 

Max Angular Velocity

Pitch: 300°/s 

Yaw: 150°/s 

Max Tilt Angle 35° 

Max Ascent Speed 5 

m/s 

Max Descent Speed

4 m/s 

Max Speed

22 m/s (ATTI mode, no wind) Max 

Flight Altitude

4500 m 

Max Wind Speed Resistance

10 m/s 

Max Flight Time

Approximately 18 minutes 

Motor Model

DJI 3510 

Propeller Model

DJI 1345 

Indoor Hovering

Enabled by default 

Operating Temperature Range

-10° to 40° C 

Diagonal Distance

559 to 581 mm 

Dimensions

438x451x301 mm 
39

Gimbal Model

ZENMUSE X3 

Output Power (With Camera)

Static: 9 W 

In Motion: 11 W 

Operating Current Station: 

750 mA 

Motion: 900 mA 

Angular Vibration Range

±0.03° 

Mounting

Detachable 

Controllable Range Pitch: 

-90° to +30° 

Pan: ±320° 

Mechanical Range

Pitch: -125° to +45° 

Pan: ±330° 

Max Controllable Speed

Pitch: 120°/s 

Pan: 180°/s
40

Camera Name

X3 

Model

FC350 

Total Pixels

12.76M 

Effective Pixels

12.4M 

Image Max Size

4000x3000 

ISO Range

100-3200 (video) 

100-1600 (photo) 

Electronic Shutter 

Speed 8s - 1/8000s 

FOV (Field Of View)

94° 

CMOS

Sony EXMOR 1/2.3” 

Lens

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

9 Elements in 9 groups 

Anti-distortion 

Still Photography Modes

Single shoot 

Burst shooting: 3/5/7 frames 

Auto Exposure Bracketing (AEB): 3/5 bracketed frames at 0.7EV Bias 

Time-lapse 

Video Recording Modes

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

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

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

Max Bitrate Of Video Storage

60 Mbps 

Supported File Formats

FAT32/exFAT 

Photo: JPEG, DNG 

Video: MP4/MOV (MPEG-4 AVC/H.264) 

Supported SD Card Types

Micro SD 

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

Operating Temperature Range

0° to 40° C 
41

Remote 

Controller 

Name

C1 

Operating Frequency

922.7~927.7 MHz (Japan Only) 

5.725~5.825 GHz 2.400~2.483 

GHz 

Transmitting Distance (Outdoor And Unobstructed)

2 km 

EIRP

10dBm@900m, 13dBm@5.8G, 20dBm@2.4G 

Video Output Port

USB, mini-HDMI 

Power Supply

Built-in battery 

Charging

DJI charger 

Dual User Capability

Host-and-Slave connection 

Mobile Device Holder

Tablet or Phone 

Max Mobile Device Width

170mm 

Output Power

9 W 

Operating Temperature Range -10° 

to 40° C 

Storage Temperature Range

Less than 3 months: -20° to 45° C 

More than 3 months: 22° to 28° C 

Charging Temperature Range

0-40° C Battery

6000 mAh LiPo 2S 

Charger Model

A14-100P1A 

Voltage

26.3 V Rated 

Power

100 W 
42

Battery 

(Standard) 

Name

Intelligent Flight Battery 

Model

TB47 

Capacity

4500 mAh 

Voltage

22.2 V 

Battery Type

LiPo 6S High voltage battery 

Energy

99.9 Wh 

Net Weight

570 g 

Operating Temperature Range -

10° to 40° C 

Storage Temperature Range

Less than 3 months: -20° to 45° C 

More than 3 months: 22° C to 28° C 

Charging Temperature Range

0° to 40° C 

Max Charging Power

180 W

Vision 

Positioning 

Velocity Range

Below 8 m/s (2 m above ground) 

Altitude Range

5-500 cm 

Operating Environment

Brightly lit (lux > 15) patterned surfaces 

Operating Range

0-250 cm 
43

EXHIBIT – B

DJI Inspire 1 Manufacturer’s User Manual

http://download.djiinnovations.com/downloads/inspire_1/en/Inspire_1_User_Manual_v1.2_en.pdf
44

Exhibit – C

DJI Inspire 1 Maintenance Manual

http://download.djiinnovations.com/downloads/inspire_1/en/Inspire_1_Maintenance_ManualV1.0_en.pdf
45

EXHIBIT – D

Monthly Maintenance Log 

EXHIBIT – D 

MONTHLY MAINTENANCE LOG

month: year: 

UAS #: 

Date Issue 

Discovered 

Date Issue 

Addressed 

Issue Description & Maintenance Conducted Maintenance Performed By: Print & 

Sign 

Software Updates 

Airframe 

Engines 

Propellers 

Camera Gimbal 

Landing Gear 

Vibration Dampening 

Other: 
46

Christopher Earle-Handley 

Air-Reelz LLC 

22 Country Club Drive Apt 29 

Manchester, NH 03102 

Tel: (978) 347-596

Email: info@air-reelz.com