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U.S. Department of Transportation

Docket Management System

1200 New Jersey Ave, SE

Washington, DC 20590

Robert Wessel

D/B/A SKYWAYVISIONS LLC

FAA ATP Certificate 2250488

11995 Shenandoah Road

Middletown, Ca

95461

June 16, 2015

Re:

Petition for exemption for Civil Commercial Operations of a small Unmanned 

Aircraft System (UAS) weighing under 55 pounds for low altitude 

photography and videography missions under the FAA Modernization and 

Reform Act of 2012 (P.L. 112-95) Sec, 333. Special Rules for Certain 

Unmanned Aircraft Systems 

Name And Address Of The Petitioner:

Robert Wessel 

D/B/A SKYWAYVISIONS LLC

11995 Shenandoah Road

Middletown, Ca 95461

Table of Contents:

1. Introduction

2. Preface

3. Basis for petition

4. Current and future scope of operations and how this request would 

benefit the public as a whole.
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5. 14 CFR Sections from which relief is sought including the reasons and 

extent relief is requested including reasons why the exemption would not 

adversely affect safety, or how the exemption would provide a level of 

safety at least equal to the existing rule:

14 CFR Part 21, Subpart H

14 CFR §45.23

14 CFR §45.33

 §61.23 

§61.56 

§91.7 

§91.9 

§91.103

§91.109 

§91.121

§91.151

§91.203 

§91.405(a),

§91.407(a)(1),

§91.409(a)(1) & (a)(2),

§91.417(a) & (b),

6. Request and reasons to exercise exemption in Mexico 

7. Summary

8. Additional information and documents.

 2015_3_Inspire_1_User_Manual_v1.2_en.pdf

 2015_4_14_Inspire_1_Release_Notes_en.pdf

 150529_wessel_CA_SOS.pdf

 Sectional Map Segments of local operations area:

 B2.pdf

 B3.pdf

 Attached checklists:

 R_Wessel_SKYWAYVISIONS LLC PRE.pdf

 R_Wessel_SKYWAYVISIONS LLC POST.pdf
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1.) Introduction

Robert Wessel is a naturalized citizen of the United States of America living in 

Lake County, California and intends to operate a small UAS doing business as 

SKYWAYVISIONS LLC a business entity name currently reserved with the 

California Secretary of State.(see attached letter) commencing immediately after 

granting of the requested privileges of the Sec 333 exemption. Mr. Wessel has over 

fifty years of flying experience ever since he soloed in 1965 at the age of sixteen. 

Mr. Wessel currently holds an FAA Airline Pilot Certificate Single and 

Multiengine with Commercial Glider privileges [ATP Certificate # 2250488]. Mr. 

Wessel is a retired Part 135 Air Taxi Charter Pilot with over 6000 hours total flight 

time and worked as a Certified Flight Instructor with an Instrument rating logging

over 2500 hours flight instruction given, successfully training pilots from Private 

Pilot all the way to the Airline Transport Pilot certificate. Mr. Wessel also has over 

twenty years experience in photography and video production with a BA Degree in 

Film/TV from Pennsylvania State University. Mr. Wessel is also an active member 

of The Academy of Model Aeronautics (AMA) and member of the Aircraft 

Owners and Pilots Association (AOPA).

2.) Preface 

The Federal Aviation Act expressly grants the FAA the authority to issue exemptions. This 

statutory authority by its terms includes exempting civil aircraft, as the term is defined 

under §40101 of the Act, that includes UAS, from the requirement that all civil aircraft 

must have a current airworthiness certificate. The Administrator may grant an exemption 

from a requirement of a regulation prescribed under subsection (a) or (b) of this section or 

any sections 44702 - 44716 of this title if the Administrator finds the exemption in the 

public interest. 49 U.S.C. §44701(f) See also 49 USC §44711(a); 49 USC §44704; 14 CFR 

§91.203 (a) (1).

Robert Wessel D/B/A SKYWAYVISIONS LLC will utilize and operate a DJI 

Inspire 1 Model T600 aircraft with two remote controls. The Master remote 

controller will be used by the Pilot In Command (PIC)/Operator and the slave 

controller will be used by the Photographer /Videographer controlling the 

proprietary DJI X3 camera payload allowing the PIC/Operator to have 100% of his 

attention on safely flying the aircraft while maintain visual line of sight (VLOS) 
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operations at all times. Although the Photographer /Videographer can also act as a 

Visual Observer (VO) for safety reasons a third person will be used as a VO when 

mandated by the complexity of certain flying environments and to insure no unauthorized persons/vehicles create distractions or travel under the flight path 

during the operation of the UAS. The UAS will be operated at a maximum altitude 

of 400 feet AGL in daylight Visual Meteorological Conditions (VMC). All Robert 

Wessel D/B/A SKYWAYVISIONS LLC operational personnel will be responsible 

for listening and scanning the surrounding airspace for other aircraft or flying 

birds. and the PIC/Operator will yield right-of-way, take emergency evasive action

if necessary and/or safely terminate the flight to avoid any conflict with other 

aircraft or flying birds.

This aircraft has four rotors and four motors in a quadcopter configuration (X4). It is 

only capable of vertical take-off and landing. This UAS weighs less than 55 lbs. 

including payload. Can fly, under normal conditions at a speed of no more than 30 knots 

and has the capability to hover, and move in the vertical and horizontal plane 

simultaneously. This UAS is equipped with GPS and auto-return function to the 

predetermined safe landing area as well as allowing reading of magnetic interference 

that can cause loss of GPS signal. The UAS will operate only in line of sight and will 

operate only within a closed-set area of a residential or commercial listing, open 

desolate areas near rural farms, forests or a closed-set special event. Such operations 

will insure that the UAS will “not create a hazard to users of the national airspace 

system or the public.” (Reform Act Section 333 (b)). The Federal Aviation Act expressly 

grants the FAA the authority to issue exemptions. This statutory authority by its terms 

includes exempting civil aircraft, as the term is defined under §40101 of the Act, that 

includes UAS, from the requirement that all civil aircraft must have a current 

airworthiness certificate.

3.) Basis for Petition

Petitioner, Robert Wessel D/B/A SKYWAYVISIONS 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 Phantom 1 Inspire model T600 , in the National 

Airspace System (NAS), and for an exemption from the requirements of CFR 14 

Sections listed below and in 5.) of the table of contents .
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4.) Current and future scope of operations in the public interest.

All Robert Wessel D/B/A SKYWAYVISIONS LLC operations will be conducted 

in the public interest, benefiting Real Estate professionals, and vacation property 

owners by augmenting Real Estate listings with aerial video. Another public 

benefit will be showcasing the beauty and splendor of Lake County, California 

scenery for county residents and others. Future public benefits will be documenting 

local forestry/timber projects in cooperation with the South Lake County Fire Safe 

Council, local Cal Fire and timber management professionals. Video and 

photography missions would include fire break surveys, identifying trees with Pine 

Bark Beetle infestations and other drought based forestry problems, all clearly in 

the public interest. Additional possible future missions would include aerial 

surveys for construction projects, tower/solar panel inspections and agricultural 

land inspections. Adding to the public interest, the inherent design of the DJI 

Inspire 1 T600 utilizes smart battery technology which will add zero fossil fuel 

pollution to the atmosphere and preclude the use of expensive manned aircraft 

flying at potentially dangerous low altitudes that would be otherwise be used for 

some or all of these missions in the past. Another public benefit created by Robert 

Wessel D/B/A SKYWAYVISIONS LLC will be job creation and income for 

operational personnel as well as other future employees.

Robert Wessel D/B/A SKYWAYVISIONS LLC will normally be conducted in 

rural non-congested areas in Class G airspace at a maximum altitude of 400’ AGL 

in daylight Visual Metrological Conditions (VMC) only with permission of 

property owners or those authorized to grant permission for access to the closed 

area to be filmed. Other operations will be conducted under a current applicable 

FAA Certificate of Authorization (COA).

5.) 14 CFR Sections from which relief is sought including the reasons and 

extent relief is requested including reasons why the exemption would not 

adversely affect safety, or how the exemption would provide a level of safety 

at least equal to the existing rule:

14 CFR Part 21, Subpart H: Airworthiness Certificates 

Subpart H, establishes the procedural requirements for the issuance of airworthiness certificates as 

required by FAR §91.203(a) (1).
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Relief is sought because Section 333 of the Reform Act both authorizes 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, in 

the restricted environment and under the conditions 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. The 

UAS to be operated hereunder is less than 55 lbs fully loaded, carries neither a 

pilot nor passengers, carries no explosive materials or flammable liquid fuels, and 

operates exclusively within a controlled area. Robert Wessel D/B/A

SKYWAYVISIONS LLC operations under this exemption will be tightly 

controlled and monitored. Application of these same criteria demonstrates that 

there is no credible threat to national security posed by the UAS, due to its size, 

speed of operation, location of operation, lack of explosive materials or flammable 

liquid fuels, and inability to carry a substantial external load. Given the size and 

limited operating area associated with the aircraft to be utilized by the Petitioner, 

an exemption from Part 21 Subpart H meets the requirements of an equivalent 

level of safety under Part 11 and Section 333 of the Reform Act. The Federal 

Aviation Act (49 U.S.C. §44701). 

CFR 14 §45.23 Display of marks; general.

(a) Each operator of an aircraft must display on that aircraft marks consisting of the Roman capital letter 

“N” (denoting United States registration) followed by the registration number of the aircraft. Each suffix 

letter used in the marks displayed must also be a Roman capital letter. 

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

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

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

letters not less than 2 inches nor more than 6 inches high, the words “limited,” “restricted,” “light-sport,” 

“experimental,” or “provisional,” as applicable.

[Doc. No. 8093, Amdt. 45-5, 33 FR 450, Jan. 12, 1968, as amended by Amdt. 45-9, 42 FR 41102, Aug. 

15, 1977; Amdt. 45-24, 69 FR 44863, July 27, 2004]

Relief is sought from CFR 14 §45.23 since the UAS will have no entrance to the 

cabin, cockpit or pilot station on which the word "Experimental" can be placed.

Given the size of the UAS, two-inch lettering will be impossible. Sub-scale or small 

UAS, or UAS of a non-conventional shape such as a multi-rotor (quad-copter, octo-copter, 

etc.) or ducted fan may not be able to comply with Part 45 or the guidance in AC 45-2D 

because of size or space limitations on the aircraft. In these cases, markings may be as large as 

practicable, or a person may apply to the FAA for an alternative marking procedure. See 14 

CFR §§ 45.22(d); 45.29(f). The word "Experimental" will be placed on the fuselage 
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in compliance with §45.29(f) until a standard registration number can be attained

as required under CFR 14 §45.33 . The equivalent level of safety will be provided 

by having the UAS marked on its fuselage as required by §45.29(f) where the 

operator working with the UAS will see the identification of the UAS as 

"Experimental" until a standard “N” number is applied for and attained.

§47.33 Aircraft not previously registered anywhere.

(a) A person who is the owner of an aircraft that has not been registered under 49 U.S.C. 44101-

44104, under other law of the United States, or under foreign law, may register it under this part 

if he—

(1) Complies with §§47.3, 47.7, 47.8, 47.9, 47.11, 47.13, 47.15, and 47.17, as applicable; and 

(2) Submits with his Aircraft Registration Application, AC Form 8050-1, an Aircraft Bill of Sale, 

AC Form 8050-2, signed by the seller, an equivalent bill of sale, or other evidence of ownership 

authorized by §47.11

Temporary relief is sought until pending procedures as required under §47.33 are 

completed and the Aircraft Registration Application, AC Form 8050-1 is filed. 

An equivalent level of safety will be attained in the interim by complying with 

alternative marking in lieu of the pending “N” number as described in the previous 

paragraph requesting relief from CFR 14 §45.23. 

§61.23 Medical certificates: Requirement and duration.

(a) Operations requiring a medical certificate. Except as provided in paragraphs (b) and (c) of 

this section, a person—

(1) Must hold a first-class medical certificate:

(i) When exercising the pilot-in-command privileges of an airline transport pilot certificate;

b) Operations not requiring a medical certificate. A person is not required to hold a medical 

certificate—

(1) When exercising the privileges of a student pilot certificate while seeking—

(i) A sport pilot certificate with glider or balloon privileges; or

(ii) A pilot certificate with a glider category rating or balloon class rating;
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(2) When exercising the privileges of a sport pilot certificate with privileges in a glider or 

balloon;

Relief is sought for §61.23(a) since piloting a small UAS does not require an 

Airline Transport Certificate. However for the purposes of §61.23, the Petitioner 

meets the requirement of §61.23(d)(ii) because he holds a glider category rating. 

The equivalent level of safety is further enhanced because the Petitioner holds a 

valid California Class B Drivers license requiring a medical examine every two 

years. (drivers license information is available if requested by the Administrator)

§61.56 Flight review

(a) Except as provided in paragraphs (b) and (f) of this section, a flight review consists of a minimum of 1 

hour of flight training and 1 hour of ground training. The review must include: 

(1) A review of the current general operating and flight rules of part 91 of this chapter; and 

(2) A review of those maneuvers and procedures that, at the discretion of the person giving the review, are 

necessary for the pilot to demonstrate the safe exercise of the privileges of the pilot certificate. 

(b) Glider pilots may substitute a minimum of three instructional flights in a glider, each of which 

includes a flight to traffic pattern altitude, in lieu of the 1 hour of flight training required in paragraph (a) 

of this section. 

(c) Except as provided in paragraphs (d), (e), and (g) of this section, no person may act as pilot in 

command of an aircraft unless, since the beginning of the 24th calendar month before the month in which 

that pilot acts as pilot in command, that person has—

(1) Accomplished a flight review given in an aircraft for which that pilot is rated by an authorized 

instructor and 

(2) A logbook endorsed from an authorized instructor who gave the review certifying that the person has 

satisfactorily completed the review. 

(d) A person who has, within the period specified in paragraph (c) of this section, passed any of the 

following need not accomplish the flight review required by this section:

(1) A pilot proficiency check or practical test conducted by an examiner, an approved pilot check airman, 

or a U.S. Armed Force, for a pilot certificate, rating, or operating privilege.

(2) A practical test conducted by an examiner for the issuance of a flight instructor certificate, an 

additional rating on a flight instructor certificate, renewal of a flight instructor certificate, or reinstatement 

of a flight instructor certificate.
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(e) A person who has, within the period specified in paragraph (c) of this section, satisfactorily 

accomplished one or more phases of an FAA-sponsored pilot proficiency award program need not 

accomplish the flight review required by this section. 

(f) A person who holds a flight instructor certificate and who has, within the period specified in paragraph 

(c) of this section, satisfactorily completed a renewal of a flight instructor certificate under the provisions 

in §61.197 need not accomplish the one hour of ground training specified in paragraph (a) of this section.

(g) A student pilot need not accomplish the flight review required by this section provided the student 

pilot is undergoing training for a certificate and has a current solo flight endorsement as required under 

§61.87 of this part.

(h) The requirements of this section may be accomplished in combination with the requirements of §61.57 

and other applicable recent experience requirements at the discretion of the authorized instructor 

conducting the flight review. 

(i) A flight simulator or flight training device may be used to meet the flight review requirements of this 

section subject to the following conditions:

(1) The flight simulator or flight training device must be used in accordance with an approved course 

conducted by a training center certificated under part 142 of this chapter.

(2) Unless the flight review is undertaken in a flight simulator that is approved for landings, the applicant 

must meet the takeoff and landing requirements of §61.57(a) or §61.57(b) of this part.

(3) The flight simulator or flight training device used must represent an aircraft or set of aircraft for which 

the pilot is rated.

[Doc. No. 25910, 62 FR 16298, Apr. 4, 1997; Amdt. 61-103, 62 FR 40898, July 30, 1997; Amdt. 61-104, 

63 FR 20287, Apr. 23, 1998; Amdt. 61-124, 74 FR 42550, Aug. 21, 2009; Amdt. 61-131, 78 FR 56828, 

Sept. 16, 2013]

Relief is sought only for flight operations involving a small UAS operated by Robert 

Wessel D/B/A SKYWAYVISIONS LLC because a flight review in a conventional 

aircraft would have no relevance to flying a small UAS from the ground and 

compliance would create an undue time and financial burden on Robert Wessel 

D/B/A SKYWAYVISIONS LLC. An equivalent level of safety intended by the 

regulation for pilot training/proficiency will be accomplished with logged practice

time on Blade Nana QX micro-drones using identical control systems as the DJI 

Inspire 1 flown inside safely out of the National Airspace System and not subject 

to FAA regulations. Given the non-GPS stabilized and extremely sensitive flight 

properties, the Blade Nano QX is an extremely practical training platform

requiring a high of skill to fly. Other training and proficiency will be accomplished 

with the DJI Inspire 1 as a model aircraft under hobby/recreational regulations, 

reviewing DJI provided tutorials, and participating in any appropriate 

training/instruction offered by DJI Inc. or any other industry qualified 
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organizations. Robert Wessel D/B/A SKYWAYVISIONS LLC personnel will review

this document and any updated general operating and flight rules of FAR Part 91 as 

intended by the regulation. Robert Wessel D/B/A SKYWAYVISIONS LLC personnel 

will also review and have on hand, during any flight, current Sectional and Terminal Area 

Charts as necessary to ensure no incursion into other than Class G airspace unless 

operating under a valid Certificate of Authorization (COA) granting apecific 

permission to operate in other than Class G airspace.

§91.7 Civil aircraft airworthiness.

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

(b) The pilot in command of a civil aircraft is responsible for determining whether that aircraft is in 

condition for safe flight. The pilot in command shall discontinue the flight when unairworthy mechanical, 

electrical, or structural conditions occur. 

.

Relief is sought because the DJI Inspire 1 UAS does not require an airworthiness certificate in 

accordance with 14 C.F.R. Part 21, Subpart H. Therefore, Robert Wessel D/B/A 

SKYWAYVISIONS LLC will ensure that the aircraft is in airworthy condition based 

upon its compliance with the Flight Test procedures specified in the DJI Inspire 1 

Users Manual as well as the Robert Wessel D/B/A SKYWAYVISIONS LLC PreFlight check list to provide an equivalent level of safety intended by the regulation.

§91.9 Civil aircraft flight manual, marking, and placard requirements.

(a) Except as provided in paragraph (d) of this section, no person may operate a civil aircraft without 

complying with the operating limitations specified in the approved Airplane or Rotorcraft Flight Manual, 

markings, and placards, or as otherwise prescribed by the certificating authority of the country of registry. 

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

(1) For which an Airplane or Rotorcraft Flight Manual is required by §21.5 of this chapter unless there is 

available in the aircraft a current, approved Airplane or Rotorcraft Flight Manual or the manual provided 

for in §121.141(b); and 

(2) For which an Airplane or Rotorcraft Flight Manual is not required by §21.5 of this chapter, unless 

there is available in the aircraft a current approved Airplane or Rotorcraft Flight Manual, approved 

manual material, markings, and placards, or any combination thereof.

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

with part 45 of this chapter. 

(d) Any person taking off or landing a helicopter certificated under part 29 of this chapter at a heliport 

constructed over water may make such momentary flight as is necessary for takeoff or landing through 

the prohibited range of the limiting height-speed envelope established for the helicopter if that flight 

through the prohibited range takes place over water on which a safe ditching can be accomplished and if 

the helicopter is amphibious or is equipped with floats or other emergency flotation gear adequate to 

accomplish a safe emergency ditching on open water. 

Relief is sought because the UAS, given its size and configuration has no ability or 

place to carry such a flight manual on the aircraft, not only because there is no pilot 
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on board, but because there is no room or capacity to carry such an item on the 

aircraft. The equivalent level of safety will be maintained by keeping the DJI 

Inspire 1 User Manual and Robert Wessel D/B/A SKYWAYVISIONS LLC check 

lists at the ground control point where the operator flying the UAS will have 

immediate access to them.

§91.103 Preflight action.

Each pilot in command shall, before beginning a flight, become familiar with all available information 

concerning that flight. This information must include—

(a) For a flight under IFR or a flight not in the vicinity of an airport, weather reports and forecasts, fuel 

requirements, alternatives available if the planned flight cannot be completed, and any known traffic 

delays of which the pilot in command has been advised by ATC; 

(b) For any flight, runway lengths at airports of intended use, and the following takeoff and landing 

distance information: 

(1) For civil aircraft for which an approved Airplane or Rotorcraft Flight Manual containing takeoff and 

landing distance data is required, the takeoff and landing distance data contained therein; and

(2) For civil aircraft other than those specified in paragraph (b)(1) of this section, other reliable 

information appropriate to the aircraft, relating to aircraft performance under expected values of airport 

elevation and runway slope, aircraft gross weight, and wind and temperature. 

Relief is sought because an FAA approved Airplane or Rotorcraft Flight Manual 

containing takeoff and landing distance data does not exist for the DJI Inspire 1 

and because runways are not needed for takeoff and landing and all flights will be 

conducted in Daylight Visual Meteorological Conditions (VMC). An equivalent 

level of safety will be provided as the operator will take all prudent actions 

including reviewing weather (wind . temperature and precipitation), flight battery 

requirements, landing and takeoff locations, aircraft performance data and 

accomplishing pre-flight checklists before initiation of flight.

§91.109 Flight instruction; Simulated instrument flight and certain flight tests.

(a) No person may operate a civil aircraft (except a manned free balloon) that is being used for flight 

instruction unless that aircraft has fully functioning dual controls. However, instrument flight instruction 

may be given in an airplane that is equipped with a single, functioning throw over control wheel that 

controls the elevator and ailerons, in place of fixed, dual controls, when—

(1) The instructor has determined that the flight can be conducted safely; and 

(2) The person manipulating the controls has at least a private pilot certificate with appropriate category 

and class ratings. 

(b) An airplane equipped with a single, functioning throwover control wheel that controls the elevator and 

ailerons, in place of fixed, dual controls may be used for flight instruction to conduct a flight review 

required by §61.56 of this chapter, or to obtain recent flight experience or an instrument proficiency check 

required by §61.57 when—

(1) The airplane is equipped with operable rudder pedals at both pilot stations;

(2) The pilot manipulating the controls is qualified to serve and serves as pilot in command during the 

entire flight;
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(3) The instructor is current and qualified to serve as pilot in command of the airplane, meets the 

requirements of §61.195(b), and has logged at least 25 hours of pilot-in-command flight time in the make 

and model of airplane; and

(4) The pilot in command and the instructor have determined the flight can be conducted safely.

(c) No person may operate a civil aircraft in simulated instrument flight unless—

(1) The other control seat is occupied by a safety pilot who possesses at least a private pilot certificate 

with category and class ratings appropriate to the aircraft being flown. 

(2) The safety pilot has adequate vision forward and to each side of the aircraft, or a competent observer 

in the aircraft adequately supplements the vision of the safety pilot; and 

(3) Except in the case of lighter-than-air aircraft, that aircraft is equipped with fully functioning dual 

controls. However, simulated instrument flight may be conducted in a single-engine airplane, equipped 

with a single, functioning, throw over control wheel, in place of fixed, dual controls of the elevator and 

ailerons, when—

(i) The safety pilot has determined that the flight can be conducted safely; and 

(ii) The person manipulating the controls has at least a private pilot certificate with appropriate category 

and class ratings. 

(d) No person may operate a civil aircraft that is being used for a flight test for an airline transport pilot 

certificate or a class or type rating on that certificate, or for a part 121 proficiency flight test, unless the 

pilot seated at the controls, other than the pilot being checked, is fully qualified to act as pilot in command 

of the aircraft. 

[Doc. No. 18334, 54 FR 34294, Aug. 18, 1989, as amended by Amdt. 91-324, 76 FR 54107, Aug. 31, 

2011]

Relief is sought because UASs and remotely piloted aircraft, by their design do not 

have fully functional dual controls. Flight control is accomplished through the use 

of a control box that communicates with the aircraft via a radio data link. The FAA 

has approved exemptions for flight training without fully functional dual controls 

for a number of aircraft and for flight instruction in experimental aircraft. The 

equivalent level of safety is provided by the fact that neither a pilot nor passengers 

will be carried in the aircraft and by the size and speed of the aircraft. Pilot training 

and proficiency will be accomplished with practice on Blade Nana QX microdrones using identical control systems as the DJI Inspire 1 flown inside and 

therefore safely out of the National Airspace System. Given the non-GPS 

stabilized and extremely sensitive flight properties, the Blade Nano is extremely

practical training platform .Other training and proficiency will be accomplished 

with the DJI Inspire 1 or other small UAS flown as a model aircraft under 

hobby/recreational regulations and parameters as specified under Pubic Law 112-

95, Title lll , Subtitle B- Unmanned Aircraft Systems (FAA Modernization and 

Reform Act of 2012) SEC. 336. SPECIAL RULE FOR MODEL AIRCRAFT.

.

§91.121 Altimeter settings.

(a) Each person operating an aircraft shall maintain the cruising altitude or flight level of that aircraft, as 

the case may be, by reference to an altimeter that is set, when operating—

(1) Below 18,000 feet MSL, to—

(i) The current reported altimeter setting of a station along the route and within 100 nautical miles of the 

aircraft; 
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(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; or 

(2) At or above 18,000 feet MSL, to 29.92′′ Hg. 

Relief is sought because the DJI Inspire 1 does not carry a conventional altimeter 

with the capability to be manually set. An equivalent level of safety intended by 

the regulation is attained because the DJI Inspire 1 determines altitude with 

multiple satellite GPS positioning signals and an automatic barometric sensor.

§91.151 Fuel requirements for flight in VFR conditions.

(a) No person may begin a flight in an airplane under VFR conditions unless (considering wind and 

forecast weather conditions) there is enough fuel to fly to the first point of intended landing and, assuming 

normal cruising speed—

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

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

(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. 

Relief is sought because there will be no cross country flights since the first point 

of intended landing will be the original takeoff zone. An equivalent level of safety 

intended by the regulation will be achieved by sufficiently charged batteries and 

the DJI 1 Inspire is equipped with a critical battery level failsafe mode that will 

automatically return and land the aircraft before battery power is lost. The PIC will 

monitor the battery levels during the flight. Robert Wessel D/B/A 

SKYWAYVISIONS LLC standard operations will require the PIC to pre-set the 

DJI Pilot App battery level warning to 20% . The PIC will begin terminating the 

flight normally at the 20% battery life warning level and will not rely on the 

automatic critical battery failsafe mode.

§91.203 Civil aircraft: Certifications required.

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

following: 

(1) An appropriate and current airworthiness certificate. Each U.S. airworthiness certificate used to 

comply with this subparagraph (except a special flight permit, a copy of the applicable operations 

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

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

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

assigned to the aircraft under part 47 of this chapter. However, the airworthiness certificate need not have 

on it an assigned special identification number before 10 days after that number is first affixed to the 

aircraft. A revised airworthiness certificate having on it an assigned special identification number, that has 
Page 14 of 19

been affixed to an aircraft, may only be obtained upon application to an FAA Flight Standards district 

office. 

(2) An effective U.S. registration certificate issued to its owner or, for operation within the United States, 

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

certification issued under the laws of a foreign country.

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

this section or a special flight authorization issued under §91.715 is displayed at the cabin or cockpit 

entrance so that it is legible to passengers or crew. 

(c) No person may operate an aircraft with a fuel tank installed within the passenger compartment or a 

baggage compartment unless the installation was accomplished pursuant to part 43 of this chapter, and a 

copy of FAA Form 337 authorizing that installation is on board the aircraft. 

(d) No person may operate a civil airplane (domestic or foreign) into or out of an airport in the United 

States unless it complies with the fuel venting and exhaust emissions requirements of part 34 of this 

chapter.

[Doc. No. 18334, 54 FR 34292, Aug. 18, 1989, as amended by Amdt. 91-218, 55 FR 32861, Aug. 10, 

1990; Amdt. 91-318, 75 FR 41983, July 20, 2010]

Relief is requested because the UAS fully loaded weighs no more than 55 lbs and 

is operated without an on board pilot. As such, there is no ability or place to carry 

certification and registration documents or to display them on the UAS. The UAS 

uses electrical battery power so fuel venting and exhaust emission requirements do 

not apply. An equivalent level of safety will be achieved by keeping any required 

documents at the ground control point where the operator flying the UAS will have 

immediate access to them. 

§91.405 Maintenance required.

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;

(b) Shall ensure that maintenance personnel make appropriate entries in the aircraft maintenance records 

indicating the aircraft has been approved for return to service; 

(c) Shall have any inoperative instrument or item of equipment, permitted to be inoperative by 

§91.213(d)(2) of this part, repaired, replaced, removed, or inspected at the next required inspection; and 

(d) When listed discrepancies include inoperative instruments or equipment, shall ensure that a placard 

has been installed as required by §43.11 of this chapter. 

§91.407 Operation after maintenance, preventive maintenance, rebuilding, or alteration.

(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; and 

(2) The maintenance record entry required by §43.9 or §43.11, as applicable, of this chapter has been 

made. 
Page 15 of 19

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

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

affected its operation in flight until an appropriately rated pilot with at least a private pilot certificate flies 

the aircraft, makes an operational check of the maintenance performed or alteration made, and logs the 

flight in the aircraft records. 

(c) The aircraft does not have to be flown as required by paragraph (b) of this section if, prior to flight, 

ground tests, inspection, or both show conclusively that the maintenance, preventive maintenance, 

rebuilding, or alteration has not appreciably changed the flight characteristics or substantially affected the 

flight operation of the aircraft.

(Approved by the Office of Management and Budget under control number 2120-0005)

§91.409 Inspections.

(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.

No inspection performed under paragraph (b) of this section may be substituted for any inspection 

required by this paragraph unless it is performed by a person authorized to perform annual inspections 

and is entered as an “annual” inspection in the required maintenance records. 

(b) Except as provided in paragraph (c) of this section, no person may operate an aircraft carrying any 

person (other than a crewmember) for hire, and no person may give flight instruction for hire in an 

aircraft which that person provides, unless within the preceding 100 hours of time in service the aircraft 

has received an annual or 100-hour inspection and been approved for return to service in accordance with 

part 43 of this chapter or has received an inspection for the issuance of an airworthiness certificate in 

accordance with part 21 of this chapter. The 100-hour limitation may be exceeded by not more than 10 

hours while en route to reach a place where the inspection can be done. The excess time used to reach a 

place where the inspection can be done must be included in computing the next 100 hours of time in 

service.....

§91.417 Maintenance records.

(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—
Page 16 of 19

(i) A description (or reference to data acceptable to the Administrator) of the work performed; and 

(ii) The date of completion of the work performed; and 

(iii) The signature, and certificate number of the person approving the aircraft for return to service. 

(2) Records containing the following information: 

(i) The total time in service of the airframe, each engine, each propeller, and each rotor. 

(ii) The current status of life-limited parts of each airframe, engine, propeller, rotor, and appliance. 

(iii) The time since last overhaul of all items installed on the aircraft which are required to be overhauled 

on a specified time basis. 

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

the inspection program under which the aircraft and its appliances are maintained. 

(v) The current status of applicable airworthiness directives (AD) and safety directives including, for 

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 owner or operator shall make all maintenance records required to be kept by this section available 

for inspection by the Administrator or any authorized representative of the National Transportation Safety 

Board (NTSB). In addition, the owner or operator shall present Form 337 described in paragraph (d) of 

this section for inspection upon request of any law enforcement officer. 

(d) When a fuel tank is installed within the passenger compartment or a baggage compartment pursuant to 

part 43 of this chapter, a copy of FAA Form 337 shall be kept on board the modified aircraft by the owner 

or operator.

(Approved by the Office of Management and Budget under control number 2120-0005)

[Doc. No. 18334, 54 FR 34311, Aug. 18, 1989, as amended by Amdt. 91-311, 75 FR 5223, Feb. 1, 2010; 

Amdt. 91-323, 76 FR 39260, July 6, 2011]
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Relief is requested from the above 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 a Part 43 airworthiness certificate and FAA-required 

inspections are not specified for the DJI Inspire 1 UAS. An equivalent level of 

safety will be achieved because Robert Wessel D/B/A SKYWAYVISIONS LLC 

will never fly the UAS with any inoperative instrument or item of equipment as 

specified in the regulations.In addition, small UASs do not carry pilots or 

passengers and operate only in controlled areas for limited periods of time An

equivalent level of safe maintenance intended by the regulations will be 

accomplished by the operator pursuant to recommendations provided by DJI Inc. 

and Robert Wessel D/B/A SKYWAYVISIONS LLC operational procedures and 

checklists. Any major repairs will be accomplished and documented by qualified 

maintenance personnel at approved DJI Inc. repair facilities, flight tested before 

returning to service and noted in Robert Wessel D/B/A SKYWAYVISIONS LLC 

maintenance records.

7.) Request to exercise exemption in Mexico.

Robert Wessel D/B/A SKYWAYVISIONS LLC has been contacted by the 

owner of Vacation Anex (http://www.VacationAnnex.com) for a one time mission to 

augment his vacation property listings with small UAS videography in Sayulita, 

Mexico. 
Page 18 of 19

8.) Summary

Given the small size, low speeds of the small UAS involved and the closed pre-planned 

environment within which Robert Wessel D/B/A SKYWAYVISIONS LLC will operate, 

the Petitioner falls squarely within that zone of safety (an equivalent level of safety) in 

which Congress envisioned that the FAA must, by exemption, allow commercial 

operations of UASs to commence immediately. Also due to the size, low speeds of the 

small UAS involved, lack of any capability to carry dangerous payloads and the restricted 

areas in which the relevant UAS will operate, approval of the application presents no 

national security issue. Given the clear direction in Section 333 of the Reform Act, the 

authority contained in the Federal Aviation Act, as amended; the strong equivalent of 

safety and enhanced safety described by Robert Wessel D/B/A SKYWAYVISIONS 

LLC in the Petition for exemption for Civil Commercial Operations of a small 

Unmanned Aircraft System (UAS) weighing under 55 pounds for low altitude 

photography and videography missions under the FAA Modernization and Reform 

Act of 2012 (P.L. 112-95) Sec, 333. Special Rules for Certain Unmanned Aircraft 

Systems , reduction in environmental impacts, including reduced emissions associated 

with the use of conventional aircraft flying at potentially dangerous altitudesthat would 

otherwise be used for aerial inspections, surveying and photography and videography, the 

grant of the requested exemptions is in the public interest. Accordingly, the Petitioner

respectfully requests that the FAA grant the requested privileges of the exemption 

without delay.

Sincerely,

Robert Wessel

D/B/A SKYWAYVISIONS LLC 

11995 Shenandoah Road

Middletown, Ca.

95461
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8.) Additional information and document attachments.

 2015_3_Inspire_1_User_Manual_v1.2_en.pdf

 2015_4_14_Inspire_1_Release_Notes_en.pdf

 150529_wessel_CA_SOS.pdf

 Sectional Map Segments of local operations area:

 B2.pdf

 B3.pdf

 Attached checklists:

 R_Wessel_SKYWAYVISIONS LLC PRE.pdf

 R_Wessel_SKYWAYVISIONS LLC POST.pdf