UNITED STATES OF AMERICA

 DEPARTMENT OF TRANSPORTATION 

FEDERAL AVIATION ADMINISTRATION 

WASHINGTON, DC 

Regulatory Docket No. _______________ 

IN THE MATTER OF THE PETITION FOR EXEMPTION OF: 

Robert Scott Button

FOR AN EXEMPTION SEEKING RELIEF FROM THE REQUIREMENTS OF TITLE 14 OF THE 

CODE OF FEDERAL REGULATIONS 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) CONCERNING COMMERCIAL

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 October 26, 2015 

 

 

Robert Scott Button

59 Route 6A

Unit 19-5

Dennis, MA 02638
TABLE OF CONTENTS 

Page 

GLOSSARY OF 

ABBREVIATIONS.................................................................................................................3 

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

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

BACKGROUND.....................................................................................................................5 

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

NAME AND ADDRESS OF PETITIONER................................................................6 

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

Robert Scott Button SEEKS EXEMPTION........................................................7 

THE EXTENT OF RELIEF Robert Scott Button SEEKS AND 

THE REASON Robert Scott Button SEEKS THE RELIEF........................9

 

THE REASONS WHY GRANTING Robert Scott Button REQUEST

WOULD BE IN THE PUBLIC INTEREST .............................................................10

THE REASONS WHY GRANTING THE EXEMPTION WOULD NOT 

ADVERSELY AFFECT SAFETY..............................................................................12 

CONCLUSION.......................................................................................................................19 

 
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) 

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 

DJI UAV manufacturer

ESC Electronic speed control

FPV First Person View 

LI-PO Lithium Polymer battery

RCV Radio Controlled vehicle 
 

SUMMARY

Robert Scott Button seeks exemption from the requirements of 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), to operate an 

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

(FMRA). This exemption will permit Robert Scott Button to operate an Unmanned Aircraft System 

(UAS) for the commercial purpose of conducting aerial video and photography for marketing, film sets, 

real estate photography, commercials, special events, wedding cinematography, and landscape over 

certain areas of the United States. 

INTRODUCTION AND INTERESTS OF THE PETITIONER

My name is Robert Scott Button, and I am a drone operator (pilot) with expertise and knowledge in all 

aspects of operating multiple types of UAS'S along with camera set up and operation. Robert Scott 

Button also provides clients with the highest quality digital content for use in their commercial, 

personal, and non-profit multimedia projects. Robert Scott Button has 25 years of RCV experience and 

10 years of radio controlled helicopter experience. Robert Scott Button is recognized as an expert in

this field. . 

The objective of Robert Scott Button aerial video and photography operations is to provide high quality

imaging for a variety of commercial, public, and residential uses drones for clients in a safe location 

away from all obstacles and people at all times. Robert Scott Button will also provide knowledge of 

UAS and promote safe UAS operations. 
BACKGROUND 

Unmanned Aircraft Systems: DJI Inspire 1 UAS

Robert Scott Button seeks an exemption to operate DJI systems for compensation or hire within the 

NAS. DJI Inspire 1 are vertical takeoff and landing (VTOL) Unmanned Aircraft (UA) with a Ground 

Control Station (GCS) utilizing electronic tablet or smart phone systems. The DJI Inspire 1 has a 

maximum gross weight of 6 pounds 7.5 ounces, a length of 17.3 inches, width of 17.7 inches, height of 

11.8 inches, and a maximum speed of approximately 42 knots. The DJI Inspire 1UA is equipped with 

four main rotors; driven by Lithium Polymer battery powered electric motors. 

The DJI Inspire 1 UA that will be operated by Robert Scott Button 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 Markings. 

BASIS FOR PETITION 

Petitioner, Robert Scott Button , pursuant to the provisions of the Federal Aviation Regulations (14 

C.F.R. § 11.61) and the FAA Modernization and Reform Act of 2012 (FMRA), Section 333, Special 

Rules for Certain Unmanned Aircraft Systems, hereby petitions the Administrator to commercially

operate the DJI Inspire 1 UAS in the National Airspace System (NAS), and for an exemption from the 

requirements of 14 C.F.R §§ 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). 

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

aircraft and its operation, Robert Scott Button 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, Robert Scott Button 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. 

Robert Scott Button submits that the requested relief is proper since an equivalent level of safety will 

be ensured. Robert Scott Button will use experienced personnel or technicians to perform maintenance, 

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

prescribed in the operating documents (i.e., Monthly Maintenance Log, DJI Inspire 1 Instruction 

Manual). Furthermore, Robert Scott Button will document and maintain all maintenance records for the 

DJI Inspire 1 UAS. 

Relief from certain requirements of Section 61.113(a) and (b), entitled Private pilot privileges and 

limitations: Pilot in command, is requested by Robert Scott Button to the extent necessary to allow a 

Pilot in Command (PIC) holding a private pilot or higher level certificate, as well as an airman medical 

certificate, and who 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 this exemption, 

including evasive and emergency maneuvers and maintaining appropriate distances from people, 

vessels, vehicles and structures. 

Robert Scott Button 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, Robert Scott Button submits that he will ensure that the DJI Inspire 1 UAS is in an 

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

operating documents (i.e., Monthly Maintenance Log, DJI Inspire 1 Instruction Manual), and that the 

aircraft are in a condition for safe flight. 

Robert Scott Button also seeks an exemption from the requirements of Section 91.121, entitled 

Altimeter Settings, as the DJI Inspire 1 UAS will not have a typical barometric altimeter onboard. 

However, altitude information of the DJI Inspire 1 UAS 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 Robert Scott Button 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, Robert Scott Button seeks an exemption from the requirements of Section 91.151(b), 

entitled Fuel requirements for flight in VFR conditions. Robert Scott Button submits that safety will not 

be affected by operation of the 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 approximately 15.5 minutes to the first point of intended landing and, assuming normal cruising 

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

In accordance with 14 C.F.R. § 11.81, Robert Scott Button 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:

Robert Scott Button

59 Route 6A

Unit # 19-5

Dennis, MA 02638

robertbutton@comcast.net

774-836-5117

B. The Specific Sections Of 14 C.F.R. from Which Robert Scott Button Seeks Exemption.

1. Robert Scott Button Seeks Exemption From The Requirements Of Section 61.113(a) And 

(b).

Section 61.113, entitled Private pilot privileges and limitations: Pilot in command, Subsections 
(a) and (b) prescribe the following, in relevant part:

a. No person who holds a private pilot certificate may act as a pilot in command (PIC) of 

an aircraft that is carrying passengers or property for compensation or hire; nor may that 

person, for compensation or hire, act as PIC of an aircraft. 

b. A private pilot may, for compensation or hire, act as PIC of an aircraft in connection 

with any business or employment if— 

i. The flight is only incidental to that business or employment; and

ii. The aircraft does not carry passengers or property for compensation or hire. 

2. Robert Scott Button 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.

3. Robert Scott Button 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-- 

Below 18,000 feet MSL, to—

i. The current reported altimeter setting of a station along the route and within 100 

nautical miles of the aircraft;

ii. If there is no station within the area prescribed in paragraph (a)(1)(i) of this 

section, the current reported altimeter setting of an appropriate available station; 

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.

4. Robert Scott Button 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.

5. Robert Scott Button 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[.] 

6. Robert Scott Button Seeks Exemption From The Requirements Of Section 91.407(a)

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 [.]

7. Robert Scott Button 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. 
8. Robert Scott Button 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: 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.

Records containing the following information:

1. The total time in service of the airframe, each engine, each propeller, and 

each rotor.

2. The current status of life-limited parts of each airframe, engine, propeller, 

rotor, and appliance. 

3. The time since last overhaul of all items installed on the aircraft which 

are required to be overhauled on a specified time basis. 

4. 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. 

5. 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. 

6. 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: 

i. 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. 

ii. 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. 

iii. 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 Robert Scott Button Seeks And The Reason Robert Scott Button Seeks 

The Relief. 

1. Extent Of Relief Robert Scott Button Seeks And The Reason Robert Scott Button 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 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, Robert Scott Button submits that an equivalent level of safety 

will be maintained because no PIC will be allowed to operate the DJI Inspire 1 UAS unless that 

PIC has met certain flight-hour and currency requirements, demonstrating that the PIC is able to 

safely operate 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, Robert Scott Button 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 Robert Scott Button business; 

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

2. Extent Of Relief Robert Scott Button Seeks And The Reason Robert Scott Button 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 Robert Scott Button 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., Robert Scott Button Aerial Operations Manual, Monthly Maintenance Log, and 

DJI Inspire 1 Instruction Manual). Robert Scott Button 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, Robert Scott Button 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.

3. Extent Of Relief Robert Scott Button Seeks And The Reason Robert Scott Button 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 

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), Robert Scott Button seeks the requested relief because the DJI 

Inspire 1 UA’s altimeter may be set on the ground to zero feet AGL, rather than the local 

barometric pressure or field altitude, before each flight.

Considering the limited altitude of the proposed operations, relief from 14 CFR 91.121 is 

sought to the extent necessary to comply with the applicable conditions and limitations stated 

below. As more fully set forth herein, an equivalent level of safety will be maintained since the 

DJI Inspire 1 UA is equipped with a barometric pressure sensor and GPS equipment, which 

automatically ensures that a ground level pressure setting will be established prior to each 

flight, and provides the PIC with altitude information of the UA on the heads-up display of the 

GCS. 

4. Extent Of Relief Robert Scott Button Seeks And The Reason Robert Scott Button Seeks 

Relief From Section 91.151(b). 
Relief from Section 91.151(b) entitled Fuel requirements for flight in VFR conditions, is 

requested to the extent required to allow flights of the battery powered DJI Inspire 1 UAS

during daylight hours in visual meteorological conditions (VMC), under visual flight rules 

(VFR), for a total duration of 15.5 minutes to the first point of intended landing and, assuming 

normal cruising speed, to fly after that for at least 4.5 minutes. Robert Scott Button seeks the 

requested relief because without an exemption from Section 91.151(b), the flight time duration 

of the battery powered DJI Inspire 1 UAS will severely constrain the practicality of any aerial 

video or still photo flight operations that Robert Scott Button proposes to conduct pursuant to 

this Petition.

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

Inspire 1 operating documents, and Robert Scott Button proposed operating limitations, ensure 

that Robert Scott Button 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. 

5. Extent Of Relief Robert Scott Button Seeks And The Reason Robert Scott Button 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, Robert Scott Button requests relief from these 

Sections because the DJI Inspire 1 UAS do not require airworthiness certificates. As set forth 

more fully below, the DJI Inspire 1 UAS meet the conditions of FMRA Section 333 for 

operation without an airworthiness certificate.

Accordingly, Robert Scott Button will use trained technicians to perform maintenance, 

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

prescribed in the UAS operating documents (i.e., Robert Scott Button Aerial Operations 

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

Robert Scott Button will document and maintain all maintenance records for the DJI Inspire 1 

UAS. 

D. The Reasons Why Granting Robert Scott Button 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 Robert Scott Button to 

safely, efficiently, and economically perform aerial video and photography of construction 

sites, real estate, and landscape over certain areas of the United States.

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

pollution, crashes and accidents caused by pilot error and provide significant benefits to the 

economy. Notably, the benefits of Robert Scott Button 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 is 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 does not require an airport to takeoff or land. Likewise, a reduction of manned aircraft 

conducting aerial video and photography missions would result in fewer aircraft that must be 
handled by air traffic control during the ground, takeoff, departure, arrival, and landing phases 

of flight operations. 

2. The Public Will Benefit From The Safety And Efficiency Of The DJI Inspire 1 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 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 UAS

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 pounds 7.5 ounces, at the maximum gross weight with length 17.3 inches, 

widths 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 UAS are 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 Robert Scott Button, to remain 

competitive and contribute to growth of the U.S. economy. Specifically, with the rising cost of 

aviation fuel and the Environmental Protection Agency (“EPA”) regulatory actions phasing out 

leaded aviation fuels, U.S. owned and operated companies must adopt new and alternative 

technology in order to remain competitive. Operating the battery powered DJI Inspire 1 UAS is 

one such technology that not only allows companies greater operational flexibility compared to 

manned aircraft, but provides such flexibility without the high operational cost of a traditional 

manned aircraft.

By operating the DJI Inspire 1 UAS, companies such as Robert Scott Button, 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, 

Robert Scott Button proposed operation of the DJI Inspire 1 UAS would not implicate any

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

operating documents (i.e., Robert Scott Button Aerial Operations Manual, Monthly

Maintenance Log, and DJI Inspire 1 Instruction Manual) which requires property owner 

involvement as well as local law enforcement notification, and in accordance with the Federal 

Aviation Regulations, including the minimum altitude requirements of 14 C.F.R. § 91.119. 
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 Robert Scott Button Seeks Exemption. 

1. Reasons Why The DJI Inspire 1 UAS 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, Robert Scott Button 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 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—

i. 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 

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, Robert Scott Button 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. 

i. The Specifications Of The DJI Inspire 1 UAS Demonstrate Its Safe 

Characteristics.

The DJI Inspire 1 UAS do not create a hazard to users of the NAS or the public, 

or otherwise pose a threat to national security considering its size, weight, speed, 

and operational capability. 

ii. Technical Specifications Of The DJI Inspire 1 UAS.

The DJI Inspire 1 Specifications and Data Sheet, attached hereto as Appendix A, 

set the technical specifications of the DJI Inspire 1 UAS forth. 

iii. 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 at pages 45-50 of the DJI Inspire 1 User Manuals, 

attached hereto as Exhibit B. 

iv. The DJI Inspire 1 UAS Is Designed For Automatic Return To Home Point 

Or Hover In The Event Of Loss Of The Control Link Or Navigation.

When the Control Link is lost, the DJI Inspire 1 UAS will remain stationary, in 

flight, for 3 seconds or more. If, after 3 seconds, the DJI Inspire 1 UAS does not 

reacquire control link data from the GCS, the UAS will assume that the Control 

Link is lost and the UAS will return to the home position (i.e., failsafe mode) via 

GPS, and will descend to the takeoff position and shutdown. 

A complete description of the Failsafe Functions of the DJI Inspire 1 at pages 13 

through 15 DJI Inspire 1 User Manuals, attached hereto as Exhibit B .

v. The DJI Inspire 1 GCS And It’s Operation.

A complete description of the operation and specifications of the DJI Inspire 1 

GCS and flight control software is provided at pages 40 through 47 of the DJI

Inspire 1 User Manual. DJI Inspire 1 User Manuals are attached hereto as 

Exhibits B.

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

Of A Certificated Pilot in Command With A Safety Observer. 

Robert Scott Button 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. 

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

Operating Limitations. 

In seeking this exemption, Robert Scott Button 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 UAS

weighing less than 55 pounds maximum gross weight: DJI Inspire 1 

Unmanned Aircraft Systems. Proposed operations of any other aircraft 

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

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

operations for the purpose of aerial video and photography. 

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

4. The UA must be operated at an altitude of no more than 400 feet above 

ground level (AGL), as indicated by the procedures specified in the 

operating documents unless a special request is made and approved by 

ATC. All altitudes reported to ATC must be in feet AGL.

5. The UAS must be operated within visual line of sight (VLOS) of the PIC 

at all times. This requires the PIC to be able to use human vision unaided 

by any device other than corrective lenses, as specified on the PIC’s 

FAA-issued airman medical certificate. 

6. The use of first person view (FPV) by the PIC or safety observer (SO) is 

not permitted. 

7. All operations must utilize a safety observer (SO). The SO may be used 

to satisfy the VLOS requirement as long as the PIC always maintains 

VLOS capability. The SO and PIC must be able to communicate verbally
at all times. Electronic messaging or texting is not permitted during flight 

operations. The PIC must be designated before the flight and cannot 

transfer his or her designation for the duration of the flight. The PIC must 

ensure that the SO can perform the functions prescribed in the operating 

documents. 

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

seeing and avoiding other air traffic and other ground based 

obstacles/obstructions and is not permitted to operate the camera or other 

instruments. 

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

during UAS operations and made available to the Administrator upon 

request. If a discrepancy exists between the conditions and limitations 

contained in the grant of exemption and the procedures outlined in the 

operating documents, the conditions and limitations contained in the 

grant of exemption take precedence and must be followed. Otherwise, the 

operator must follow the procedures as outlined in its operating 

documents. The operator may update or revise its operating documents. It 

is the operator’s responsibility to track such revisions and present 

updated and revised documents to the Administrator upon request. 

The operator must also present updated and revised documents if it 

petitions for extension or amendment to the grant of exemption. If the 

operator determines that any update or revision would affect the basis 

upon which the FAA granted the exemption, then the operator must 

petition for amendment to its grant of exemption. The FAA’s UAS 

Integration Office (AFS-80) may be contacted if questions arise 

regarding updates or revisions to the operating documents.

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

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

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

until the necessary maintenance has been performed and the UAS is 

found to be in a condition for safe flight. The Ground Control Station 

must be included in the preflight inspection. All maintenance and 

alterations must be properly documented in the aircraft records.

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

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

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

conducts the functional test flight must make an entry in the aircraft 

records. 

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

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

relevant sections of the operating documents. 

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

maintenance, overhaul, replacement, inspection, and life limit 

requirements.

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

keeping requirements, in accordance with the operating documents. 

Maintenance, inspection, alterations, and status of replacement/overhaul 

component parts must be noted in the aircraft records, including total 

time in service, description of work accomplished, and the signature of 
the authorized person returning the UAS to service.

15. Any UAS operated under this exemption must comply with all 

manufacturer Safety Bulletins. 

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

corrective action taken against discrepancies discovered between 

inspections.

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

current third-class medical certificate.

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

operator’s qualification criteria and demonstrates the ability to safely 

operate the UAS in a manner consistent with how the UAS will be 

operated under the exemption, including evasive and emergency 

maneuvers and maintaining appropriate distances from persons, vessels, 

vehicles and structures. PIC qualification flight hours must be logged in a 

manner consistent with 14 C.F.R. § 61.51(b). Flights for the purposes of 

training the operator’s PICs are permitted under the terms of the 

exemption. However, training operations may only be conducted during 

dedicated training sessions. During training, proficiency, and experiencebuilding flights, all persons not essential for flight operations are 

considered nonparticipants, and the PIC must operate the UA with 

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

91.119. 

19. UAS operations may not be conducted during night, as defined in 14 

C.F.R. § 1.1. All operations must be conducted under visual 

meteorological conditions (VMC). If flight at night is required, a special 

request will be made at the FAA office closest to proposed area of 

operations. Flights under special visual flight rules (SVFR) are not 

authorized. 

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

point as denoted on a current FAA-published aeronautical chart unless a

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

operation is conducted in accordance with a NOTAM as required 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 400 feet below or less than 2,000 

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

miles from the PIC.

22. If the UA loses communications or loses its GPS signal, it must return to 

a pre-determined location within the planned operating area and land or 

be recovered in accordance with the operating documents.

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

emergencies in accordance with the operating documents. 

24. The PIC is prohibited from beginning a flight unless (considering wind 

and forecast weather conditions) there is enough power to fly at normal 

cruising speed to the intended landing point and land the UA with 25% 

battery power remaining. 

25. The operator must obtain an Air Traffic Organization (ATO) issued 

Certificate of Waiver or Authorization (COA) prior to conducting any

operations under the grant of exemption. This COA will also require the 
operator to request a Notice to Airman (NOTAM) not more than 72 hours 

in advance, but not less than 48 hours prior to the operation. All 

operations shall be conducted in accordance with airspace requirements 

in the ATO issued COA including class of airspace, altitude level and 

potential transponder requirements. 

26. All aircraft operated in accordance with the exemption must be identified 

by serial number, registered in accordance with 14 C.F.R. part 47, and 

have identification (N- Number) markings in accordance with 14 C.F.R. 

part 45, Subpart C. Markings must be as large as practicable. 

27. Before conducting operations, the radio frequency spectrum used for 

operation and control of the UA must comply with the Federal 

Communications Commission (FCC) or other appropriate government 

oversight agency requirements. 

28. The documents required fewer than 14 C.F.R. 91.9 and 91.203 must be 

available to the PIC at the Ground Control Station of the UAS any time 

the UAS is operating. These documents must be made available to the 

Administrator or any law enforcement official upon request. 

29. The UA must remain clear and yield the right of way to all manned 

aviation operations and activities at all times. 

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

vehicle. 

31. Flight operations must be conducted at least 500 feet from all 

nonparticipating persons (persons other than the PIC, SO, operator 

trainees or essential persons), vessels, vehicles, and structures unless:

a. Barriers or structures are present that sufficiently protect 

nonparticipating persons from the UA and/or debris in the event 

of an accident. The operator must ensure that nonparticipating 

persons remain under such protection. If a situation arises where 

nonparticipating persons leave such 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 Website: www.ntsb.gov. 

2. Reasons Why An Exemption From The Requirements Of Section 61.113(a) And (b) Would 
Not Adversely Affect Safety. 

Robert Scott Button 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 Robert Scott Button proposed area of operations, and the operating limitations set 

forth-above; the parallel nature of private pilot aeronautical knowledge requirements to those of 

commercial pilot requirements (See Exemption No. 11062); and the airmanship skills necessary

to safely operate the DJI Inspire 1 UAS, Robert Scott Button submits that the additional manned 

airmanship experience of a commercially certificated pilot would not correlate to the 

airmanship skills necessary for Robert Scott Button 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). Robert Scott Button will not allow any PIC to 

operate the DJI Inspire 1 UAS unless that PIC has demonstrated, by meeting minimum flighthour requirements for 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 Robert Scott Button 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:

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 experiencebuilding 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, Robert Scott Button will ensure safe operations by not allowing any PIC to 

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

CONCLUSION

Robert Scott Button 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 Robert Scott Button 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, Robert Scott 

Button respectfully requests that the Administrator grant this Petition for an exemption from the 

requirements of 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), and permit Robert Scott Button to 

operate the DJI Inspire 1 UAS commercially for the purpose of conducting aerial video and 

photography over certain areas of the United States. 

Dated: October 26, 2015 

 Submitted by 

 Robert Scott Button 

 
 APPENDIX – A

DJI INSPIRE 1 TECHNICAL SPECIFICATIONS 

Robert Scott Button only utilizes safe and reliable UAS. DJI is an industry leader in small UAS 

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

which will not allow flight into controlled airspace. Parameters can also be set to limit flight to no 

higher than a predetermined and set altitude as well as limit flight to a predetermined and set distance. 

In addition, DJI software provides real-time altitude and location information to the PIC via the linked 

monitor (smart phone/tablet devices) 

DJI Inspire 1

1.1 Aircraft

1.1.1 Model – T600

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

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

1.1.4 Max Angular Velocity – Pitch: 300/s; Yaw: 150/s

1.1.5 Max Tilt Angle - 35

1.1.6 Max Ascent Speed – 5m/s

1.1.7 Max Descent Speed – 4m/s

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

1.1.9 Max Flight Altitude – 4500m

1.1.10 Max Wind Resistance – 10m/s

1.1.11 Max Flight Time – Approximately 18 minutes

1.1.12 Motor Model – DJI 3510

1.1.13 Propeller Model – DJI 1345

1.1.14 Operating Temperature Range – 14F to 104F (-10C to 40C)

1.1.15 Dimensions – 17 1⁄4” x 17 3⁄4” x 12”

1.2 Gimbal

1.2.1 Model – ZENMUSE X3

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

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

1.2.4 Angular Vibration Range - ±0.03

1.2.5 Mounting – Detachable

1.2.6 Controllable Range – Pitch: -90 to +30; Pan: ±320

1.2.7 Mechanical Range – Pitch: -125 to 45; Pan: ±330

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

1.3 Transmitter

1.3.1 Name – C1

1.3.2 Operating Frequency – 5.728-5.850GHz; 2.400-2.483GHz

1.3.3 Communicating Distance (unobstructed) – 2000m

1.3.4 Output Power – 9W

1.3.5 Operating Temperature Range - 14F to 104F (-10C to 40C)

1.3.6 Battery – 600mAh LiPo 2S
All specifications can be found in the attached user manual or at 

http://www.dji.com/product/inspire-1/spec